## This comment letter response contains two parts:

(1) The original submittal from the commenter. (2) A data base printout of EPA’s response to each point raised by the commenter.

Notes about the response letters:

• The response letters were generated by a data base used to track the content of all public

comment submittals and ensure that the Agency responds to each. Each comment letter

was assigned a Letter ID that corresponds to the last four digits of the docket number of the original comment (as posted on www.regulations.gov).

• Each response letter includes: comment text; an EPA

‐ assigned comment code; and an individual response. These are described and explained below.

• The data base contains Comment text from the letters submitted by commenters. Many hard copy letters were scanned into electronic format for inclusion in the data
base. As a result, there may be some typographical errors attributable to optical
character recognition issues. However, all original submittals were reviewed in the

process of drafting responses to ensure that the comment content was understood and appropriately addressed.

• The content of each comment letter was divided into topic areas and assigned a unique
Comment ID. Additionally, one or more Comment Codes (i.e., unique topic area ID) was assigned to each discrete point raised by a commenter. This information was added to the data base. To inform final rulemaking decisions, all comments and information
received on a given topic were reviewed by technical experts in each rule area (e.g., on construction requirements).

• Following decisions on the final rule requirements, Individual responses were drafted by topic area to ensure completeness and consistency of the responses with the final
rule and other responses to similar comments. Each discrete point made by a
commenter was given a unique response.

• Upon completion of comment responses, all information was entered into the data base.
Each letter response is a compilation of each comment and its individual response, compiled in the order of the original comment letter. As a result of this process, there is repetition in the response text. The Agency believes this approach ensures completeness
and attention to each comment letter that was submitted.

• All comments in a topic area were reviewed, evaluated, and responded to concurrently. Responses on each topic area are compiled and are also available in the rulemaking docket.

### Environmental Protection Agency proposed Federal Requirements under the Underground Injection Control Program for Carbon Dioxide Geologic Sequestration Wells.
Proposed Regulations Published in the July 25, 2008
Federal Register Notice

Docket #: EPA-HQ-OW-2008-0390

October 13, 2009

U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, NM Washington D.C. 20460

Docket,

The Fond du Lac Band of Lake Superior Chippewa (the “Band”), a federa lly recognized tribe, appreciates the opportunity to respond to the proposed Federal Requirements Under the Underground Injection Control (UIC) Program for Carbon Dioxide (CO 2 

### ) Geologic Sequestration (GS) Wells.

The Fond du Lac Reservation and the related Ce ded Territories are located in northeastern Minnesota, a region with significant metal extrac tion activities, associated fossil fuel electric generating units, forest product industry, with l and and sea shipping hubs. The region is home to the Ojibwe people and the tribes retain usufructuary rights (hunting and gathering) in the Ceded Territories. The area has significant natural and freshwater resources including Lake Superior.
As an indigenous population, it is of primary importance to work to toward maintaining and restoring the health of the environment as a dire ct means to improve the health and welfare of the Band. As a community, we must protect and heal Omizakamigokwe , Mother Earth, the provider and live sustainably within the environment.

General The proposed rule is quite specific and seeks to compartmentalize comments only to the endangerment that may be caused to underground s ources of drinking water (USDW). However,

### the proposal goes on to state that the Class VI injection wells are to be one approach “that could be deployed to reduce CO 2 

### emissions to the atmosphere and help to mitigate climate change.”
While such specificity allows for a focused approach, if approved, it may allow Class II wells to be used for GS of CO 2 

### under the rule. The use of Class II wells for GS of CO 2 

### will likely allow carbon credits in one form or another, even though the injected CO 2 

### would be used to enhance the extraction of additional fossil fuels (oil or natural gas), which when consumed releases CO 2 

### , impeding rather than mitigating CO 2 

### emissions.
If the proposed wells are to be a part of a clim ate mitigation strategy, supporting data must be supplied to verify that goal.

Assessment of the Proposed Rule The proposed rule repeatedly references clim ate change mitigation by the injection of CO 2 

### as the justification for the need for the new class of injection well:
Summary: “EPA is proposing Federal requirement s under the Safe Drinking Water Act (SDWA) for underground injection of ca rbon dioxide (CO2) for the purpose of geologic sequestration (GS). GS is one of a portfolio of options that could be deployed to reduce CO2 emissions to the atmosphere and help to mitigate climate change.”

And “If finalized, this proposal would help ensure consistency in permitting underground injection of CO2 at GS operations ac ross the U.S. and provide requirements to prevent endangerment of USDWs in antici pation of the eventual use of GS to reduce CO2 emissions.”
In Part II “What is the EPA Proposi ng” the proposit ion reiterates: “In addition to protecting USDWs, today’ s proposed rule provides a regulatory framework to promote consistent approaches to permitting GS projects across the U.S. and supports the development of a ke y climate change mitigation technology.”

Under Part II A. “Why Is EPA Proposing To Develop New Regulations To Address GS of CO2?” Part II. Section 2, states: The Intergovernmental Panel on Climate Change (IPCC) has concluded that much of the warming in recent decades is very lik ely the result of human activities (IPCC, 2007). The burning of fossil fuels (e.g., from coalfired electric plants and othersources in the electricity and industrial sectors) is a major contributor to humaninduced greenhouse gas emissions.
Fossil fuels are expected to remain the mainstay of energy production well into the 21st century, and increased concentrati ons of CO2 are expected unless energy producers reduce the CO2 emissions to t he atmosphere. The capture and storage of CO2 would enable the continued use of coal in a manner that greatly reduces the associated CO2 emissions while other safe and affordable alternative energy sources are developed in the coming deca des. Given the United States’ abundant coal resources and reliance on coal for power generation, CCS could be a key mitigation technology for achieving domestic emissions reductions”

And: “Congressional climate change legislative proposals (the McCain-Lieberman bill S. 280, the Bingaman-Specter bill S. 1766, and the Lieberman-Warner bill S. 2191) indicate that CCS has the potential to pl ay a significant role in climate change mitigation scenarios.”

And: “Today’s proposal provides a regulatory framework to protect USDWs as this key climate mitigation technology is developed and deployed.”

### The allusion of mitigating c limate change or reducing CO 2 

### emissions by geologic sequestration cannot be fairly used as persuasive point for th is rule without providing data demonstrating the mass balance of energy and carbon dioxide in the whole system.
A great deal of analysis has been completed a nd posted on the docket of cost and incremental cost within the proposed rule for CCS and GS implementation but no analysis is made in terms of the actual amount carbon dioxide that will be se questered in relation to the amount of carbon dioxide emitted throughout the process (Cost: EPA–HQ–OW–2008–0 390-0073 and EPA–HQ– OW–2008–0390-0094).
A mass balance of the participating fossil energy processes, generating the CO 2, 

### must be evaluated to determine if any real reduction in CO 2 

### can be made. CO 2 

### is emitted during the excavation and transport of the fossil fuel to a power plant. Additional power will be required, and will emit additional CO 2 

### , to provide the energy to extract the CO 2 

### from the emission stream, to compress, transport, and to inject the CO 2 

### into a geologic formation.
Very little data is available to evaluate the energ y balance of various carbon capture processes. The evaluations available limit the efficiency of carbon capture (CC) to a percent recovered from the feed stack to the emission st ack. Capturing the carbon is very energy intensive and may increase energy demand by up to 50%. ( www.lowtechmagazine.com accessed October 27 2008).

According to Greenpeace International: False Hope: Why carbon capture and storage won't save the climate , “capturing and storing carbon uses lots of energy; anywhere from 10-40% of a power station’s capacity. An energy penalty of just 20% would require the construction of an extra power station for every four built. These reductions in efficiency will require more coal to be mined, transported, and burned, for a power station to pr oduce the same amount of energy as it did without CCS.”

The attached summary of a study by Wuppertal Institute, the German Aerospace Center (DLR), Zentrum für Sonnenenergie- und Wasserstoff-Fo rschung Baden-Württemberg (ZSW) and the Potsdam Institute for Climate Impact Research (PIK) for the German government (the full report available at: www.wupperinst.org , accessed on line Dec. 23 2008) offers an in depth study of CCS that evaluates the various power plant designs, transport, and storage costs; accesses life cycle, ecological criteria, carbon neutrality etc. Estimates in the study show a 20 to 40% increase in energy consumption and the proc ess will only lower emissions of CO 2 

### , ignoring the increases of other greenhouse gases (GHG).
Consuming an additional 20 to 50% more coal to energize the capture of CO 2 

### is a questionable tactic that must supported by transparent data analysis.

Even as this proposed rule is being considered, the EPA is soli citing “applications to conduct research to support the development of sound risk management strategies for the underground injection of anthropogenic carbon dioxid e (CO2)” (accessed online October 6 2008 http://es.epa.gov/ncer/rfa/ 2008/2008_star _gsc02.html ). The technology for GS of CO 2 

### is not yet available or known to be safe.

Social Justice: The United Nations Environmental Progamme states: “Globally around $300 billion or 0.7 per cent of global GDP is being spent on energy subsidies annually. The lion's share is being used to artificially lower or reduce the real price of fuels like oil, coal and gas or electricity generated from such fossil fuels. Cancelling these subsidies might reduce greenhouse gas emissions by as much as six per cent a year while contributi ng 0.1 per cent to global GDP.” Mr. Steiner added: "Whereas fossil fuel subsidies are an example of a blunt policy instrument, perpetuating old and inefficient economic model s, the CDM is an example of a more

### intelligent, market-based mechanism that is fo stering the transition to a modern Green Economy". (Accessed online Nov. 14, 2008 http://www.unep.org/D ocuments.Multilingual/Default.asp?DocumentID=543&ArticleID=5902 

### )

Recommendations:

• A thorough mass balance of the CO 2 

### generated in the participating fossil energy processes, generating CO 2 

### must be demonstrated to prove t he feasibility of the proposal; including mining and transport of the fossil fuel to power plants, extraction and compression of the CO 2 

### emissions, transport, and injection the CO 2 

### into a geologic formation.

• If carbon credits are developed, they must not apply to other UIC wells except specific Class V experimental wells. To use sequest ered carbon dioxide under the auspices of this rule, to enhance the recovery of addit ional fossil fuels is imprudent and illogical.

• Liability issues must be clar ified in regard to human welf are and environmental protection rather than ensuring the financial viability of the commercial entities of power plants, pipeline, and well operators. Proponents wish to diminish liability for CCS and GS activities (EPA-HQ-OW-2008- 0390-0150.1) and EPA must explic itly recognize the threat of an uncontrolled release of CO2 to hum an life. Acknowledgement of the potential hazard, in a manner similar to OSHA guidelines on 

## “ gases, vapors, fumes, dusts, and mists - 1926.55” would be beneficial.

• Fond du Lac will defer to the experts in the case of pipeline and well integrity and the long term safety of geologic sequestration of car bon dioxide. However, the skill of deep drilling brings to mind the mudflow disaster of Si doarjo Porong, East-Java Indonesia, which began in May 2006 and is still flowing to this day.

• Financial Assurance should be required for any unforeseen effects of a given project.

Conclusion: Although the effort made to address the serious issues of climate mitigation through CCS is greatly appreciated, the effort largely appears to mitigate CO2 emissions via a complex system that will, in reality, increase fossil energy consumption. With pr ojected consumpti on to increase more than 30% by 2030 and CCS adding at least 20% additional demand, one may wonder if this proposal equates to yet another su bsidy for fossil fuel industry.
The absence of analysis of the carbon neutrality of this project is a serious omission. An analysis of this kind should have been the first step in evaluating this proposal, yet it is not addressed in the rule or in any of the suppo rting documentation. An endeavor of this magnitude should be demonstrably carbon neutral and hopefully operate as a true carbon sink.
The commitment of resources; human, material, and capital, required to construct the network of pipelines and wells for a project that is most li kely energetically untenable, cannot be supported without a proper evaluation of car bon throughput of the entire process.
This rule is written for the existing energy produc tion system. The reliance on fossil energy must change to meet the challenge of climate change. Ba rriers to the success of alternate sources of energy must be removed so the issue can be fa ced head on. This rule will impede and obstruct progress for those competing industries.
The resources required to pursue this undertaking will be in direct competition with efforts focused on sustainable energy sources and alte rnative, arguably more effective carbon sequestration, utilizing wetland restoration, improved agricultural methods, and sustainable forestry practices that have num erous and vital fringe benefits.
Experts in carbon sequestration know that utilizi ng biologic methods of carbon capture is cost effective and will include economic benefits. For example, wetland protec tion and restoration will not only sequester carbon but will purify water, impede drainage (flooding), and replenish

### aquifers. Many avenues could be used to reverse engineer the activities that drained these wetlands. Many studies including the Kyoto Pr otocol Wetland Restoration and Management and the Wilderness Society Forest Carbon Report support these alternative carbon sequestration mechanisms.
Reduction of carbon emissions to the atmosphere is the primary driver for this new class of well, proof that carbon capture and sequestration will pr ovide a net removal of CO2 must be provided else any reference to the reduction of CO 2 

### emissions or climate mitigation must be removed from the document.

Respectfully,

Mary Munn Air Program Coordinator Fond du Lac Reservation 1720 Big Lake Road Cloquet MN 55720

marymunn@fdlrez.com Office: 218.878-8030

c.c. Wayne Dupuis – FdL Environmental Program Manager Dennis Peterson – FdLTribal Attorney Darrel Harmon – EPA, HQ Ben Giwojna – EPA, Region V Laura McKelvey – EPA, OAQPS Stephen Hartsfield – NTAA

(Previously submitted Dec 23 2008 to OW-GENERAL@epa.gov' and Dec 29 to d ocket Contact Lee Whitehurst)

## , Wuppertallnstitute

« m for Climate, Environment and 

### Energy 

### PIK



# RECCS

Ecological, Economic and Structural Comparison
of Renewable Energy Technologies (RIE)


# with Carbon Capture and Storage (CCS)

- 

# An Integrated Approach

Research project fundedby 

# ttl Federal Ministry for the Environment, Nature Conservation and Nuclear Safety

## IMPRINT

Publisher:

Federal Ministry for the Environment, Nature Conservation and Nuclear Safety (BMU)



### Content:

Wuppertallnstitute for Climate, Environment and Energy (WI)**Dr.~lng.** Manfred Fischediek**(co~ordjnatorl** Dip!. Umweltwiss. A"ldrea Esken**Soz,~Wiss,** Andreas Pastowski
Dipl.-Ing. Dietmar 5chOwer

Dr. Nikolaus Supers berger

German Aerospace Center (OLR) Institute of Technical Thermodynamics
Dr, Joachim Nitsch

Dr, PeterViebahn

Centre for Solar Energy and Hydrogen Research (ZSW)

Dr. Andreas Sandi

Dr. Ulrich Zuberbuhler

Potsdam Institute for Climate Impact Research (PIK)

Dr, Ottmar Edenhofer

Layout: VlsLab, Wuppertallnstitute

Print: Offset Company, Wuppert,i

Date: April 2008

Download: www.bmu.de www,wupperinst,org/en/ccs

Print run: 1,000 (long version), 1,500 (short version)

Printed copies are available with the BMU (long version and short version)

Contact: Dr.·lng, Manfred Fischedick Wuppertallnstitutefor Climate, Environment and Energy
P. 0, 60x 10 04 80 D,42004 Wuppertal

Tel: +49,202,2492,121
Fax: +49,202,2492,198**E~ma** ]1: manfred.fischedick@wupperinst.org

# Status Quo and the Aims of the Study

Long-term scenarios on the development of energy systems show that the transition to a**climate~frjendl)'** 

### energy supply will in Some 

### way Tule 

### out coaL However) coal is the fossil fuel with the largest globall'eserves**~** distributed over many regions of the world and is**sub~** jeet to fewer geopolitical risks than oil and gas.

This raises the question of how the use of coal could be
made more c1imate

w friendly. Alongside improvements in the efficiency of the various ways c:oal is used (primarily by increasing the conversion efficiency of power stations and expanding the use of combined heat and power) the technology option of carbon capture and slorage (CCS) could also make a contribution. Its**intro~** duction could make it possible to produce 'low-C0 2 ' energy based on coal. 1he important fields in this context are electricity generation, and even more so the production 

### of hydrogen 

### as a W1iversal storable 

### fueL The same a.lso 

### applies in 

### principle to natural gas and oill although from the dimate perspective natural gas is a less critical issue owing to its lower carbon intenSity.

There are 

### still many unanswered questions today concerning the possibilities of capturing CO 2 and especially storing it safely (or a very long lime. These**ques~** tions include not only how much safe, iong-term storage capacity there rKtually is for CO 2 (and its regional distribution), but also what costs and ecological risks are involved.lfCCS can be succcssfuHy introduced as a new technology option at reas,onablc cost and with**accept~** able ecological impacts, it could make a ma.jor contribution to providing a more secure and climate· friendly supply o( energy.

Previous studies in this field have tended to concentrate

on the general tech nita1 fe'Jsibilhy of the concept. There has not yet been a detailed examination of the eCQlogical, economic and social impacts along the whole
process chain (e.g, energy balance, cumulative energy demand, environmental impact, use of resources, risks) costs) of the kind that is a matter of course today for other new technologies, especially renewables. Only after such scrutiny will it be**pos~ible** to decide how envi, ronmentally beneficial this teChnology option really is, what advantages and disadvantages it has compared with renewables and what contribution it can make to a sustainable economic structure. That is the focus of the present study.

This project is particularly relevant in view of recenl political**initlative~** on international level for using the so-called 'dean coal' option, extensive research activities globally and the publication of the German Environrnent Agency's assessment of CCS from the suslain

w ability perspective in mid-2006,

More and more scientists, politicians, and NGDs are calling for investigation and consideration of'dean coal' technology, 'Ihe energy sector itself is planning to open various small CCS demonstration plant in 2008 and the following years mainly in Europe and USA.

The findings so far show that introducing carbon capture and storage only makes sense 

### if done on a large 

### scale. Given the great volume 

### of investment required and the implications for other options for reducing greenhouse gases, the decisi<.m about whether CCS should be made a central pillar of energy policy will have to be thoroughly considered on a solid scientific basis. It is already recognised today that new tech nolo· gies 

### will have to satisfy numerous technological, struc" tural, economk, ecological and social criteria before they can be regarded as viable options for a sustainable future energy supply. So they 

### will be subjected to a rigw

orous selection process before their suitability as future key technologies is accepted. As well as detailed investigation of the potential, the achievable future costs, the implications for industrial policy and social impact of a 

### technology, difFerentiated life cycle assessments (LeAs) of the whole system represent a suitable instrument for assessing the practicability of new technologies agaimt various Sllstainability criteria. Very detailed LeAs are already available for the various technologies based



### on rel')ewables, which represent one of the main other options for avoiding greenhouse gases. Suitable data for making a solid assessment of capability and**envi~** ronrnental and system impact are also already available for numerous technologies in the field of efficiency (e,g. modern combined heat and power).

The goal of this project is consequently to weigh up the range of technologies for carbon capture and storage currently under discussion in terms of their fundamental suitability for a future energy supply. We outline several reference systems and realistic system configurations for supplying electricily and hydrogen together with all the relevant data required to properly appraise and assess the options in the scope of an overall**con~** cept for a future sustainable energy supply. These make it possible to identify the fundamental potential of the proposed technologies, the technological advancements still required and the environmental impact. A systematic comparison with other options for a dirnatefriendly energy supply

- especially the use of renewabies

- concludes the stud}'. This if> the context in which the discussion about the possible role of the CCS option

### 2

in longer-Lerm energy supply scenarios must be conducted, in which the timeframe of future development steps (establishing an infrastructure) must be considered and in which fundamental energy policy decisions

must be addressed. This investigation supplies a sophisticated set of data for placing the carbon capture and storage option in the energy and especially the climate poHcy context. As such it can make an important contribution to energy pOlicy decisions currently on the agenda.

The principle research questions can be summarised as follows:

• What are the conceivable routes for CCS (technologies, infrastructures, development timetables)?

• What does the overall life cycle assessment of these

processes look like, and how does low-C0 2 fossilbased electricity compare with CO 2 -free options, especially renewables (comparison on an equal footing)?

• What role can CCS play for climate protection in comparison with other relevant options, and when (systematic comparison on the basis of significant criteria such as cost, timeframe, ecological restrictions, etc.)?

• What role can CCS playas a possible bridge to a renewable energy system?

The report has 

### five parts:

Part one (introduction and background) examines the driving forces behind CCS and the attitudes of relevant

actors.

Part two takes a closer look at technological developments in the field of CO 2 capture (in electricity generation and hydrogen production) and at the individual steps involved in CO 2 capture, transport and storage.

The third part presents a comparative assessment of 

### CCS and other relevant climate protection technologies

on the basis of a comprehensive set of criteria. The life cycle assessment method (LeA) is used to conduct a thorough comparison of the ecological performance of 

### CCS in comparison with continued expansion of renewabies. The economic parameters are also examined in greater depth. Additional criteria are used to differentiate and expand the comparison with renewables.

Part four examines the significance of CCS for national

energy sectors, including thorough system and scenario analyses. The significance of CCS and renewables for

energy and climate policy are compared, The Germany

energy system was chosen as an example. 

### Status Quo and the Aims of the StudylL

Finally, part five turns to a more global perspective on CCS, showing the requirements and preconditions that have to be met for international implementation of this technology option.

Working GIOUp WI, OLR, ZSW, PIK

# Summary of Theses

Driving Forces and the Attitude of Relevant Groups Towards (0, Capture and Storage

• Climate protection is the most important reason for developing CO 2 capture and storage. In particular sectors of the economy other economic incentives to capture CO 2 already t:xist today (e.g. enhanced oil recovery).



### • Attitudes towards the technology are not uniform in different groups of society, CCS is often described as a possible bridge to the era of renewable energy.

• Environmental organisations prioritise the further expansion of renewablcs and the full exploitation of energy-saving potentials. All environmental organisations reject the idea 

### of storing CO 2 

### in the oceans. Adequale proof of long-term stability is demanded for all storage options.

(02 

### Capture Methods

• Today there arc three technology options for CO 2 

### capture in the short to medium term. Capturing CO 2 

### from the flue gases of conventional power stations (post-combu.stion 

### capture) leads to a 

### significant increase in 

### electricity generating costs, causes a 

### comiderablc increase in 

### fuel consumption 

### and substantially reduces power station efficiency. Tn principle 

### the technology is already available today, although it has yet to be demnnstrated at
the scale of commercial power plant.



### • Capturing CO 2 

### before 

### combustion (pre-combustion 

### capture) in**coal~** 

### or gas· fired power stations with 

### integrated gasification (IGCC and natural 

### gas combined cycle) is from today's perspective a more 

### advantageous process than capluring CO 2 from flue gas. 

### Implementing this CO 2 capture 

### method would require considerable improvement and development, especially with regard to scaling 

### it up to conventional power 

### plant dimensions.

till 

### The oXjfuel 

### process invoh'es burning fuel in pure oxygen and currently offers the best
prospects for CO 2 capture in terms of the**achie\~able** 

### overall efficiency of 

### the process 

### and possibly also the resulting costs, because the components involved are largely based on conventional power station technology. A 

### precise evaluation is not yet possible, because the process is only at the beginning of the demonstration phase.

• Considerable additional costs must be factored in 

### for capture at the power 

### station,**accord~** 

### jng to current 

### estimates between €35/t and €50/t CO 2 , 

### Through research and demonstration projects and other technological improvements it 

### is aimed to reduce the costs to less than €20/t 

### CO"

., As well as planning new builds with integrated CO 2 

### capture it is in principle also possible
to retrolil. BeGlUse of 

### the strong increase in energy consumed internally, this only makes

sense in power stations which start off with a sufficienlly high level of efficiency. In terms of technology, (Jue gati 

### scrubbing is the primary option for retrofitting from today's per w 

### spective. When power stations are planned today, the option of designing them to be 'capture ready' (prepared for retrofitting CO 2 

### capture) should be considered.

RECCS ProJl!ct 

### 3

### 4 

### Summary of Theses



### Methods for (02 Transport

• Energy efficiency. economic and ecological considerations mean that pipelines (onshore, possibly offshore loo) and large tanker ships are the only relevant transport options for large-scale implementation of CCS.

• The decisive parameters for the source/sink relationship are in particular transport distance and capacity, but coordinating the timing of planning, approval and construction of power stations, pipelines and CO 2 sinks is also relevant. The high investment costs involved in establishing a CO 2 infrastructure necessitate forward-looking planning and coordination between the different parties involved.

• Both gas conditioning (liquefying CO 2 

### by compression, which reduces power station efficiency by up to 3.5 percentage points) and subsequent CO 2 transport themselves require

a more than negligible additional amount of energy, which in turn causes additional CO 2 emissions (and other greenhouse gases and pollution).

• The range of cost estimates for CO 2 is

- depending on transport distance and capacity

- approx. €lIt to €10/t (for pipeline or ship transport) and represents about 10 % of the total

costs of the CCS process (capture, compression, transport, storage).

• In relation to the other infrastructure costs (electricity transmission, fuel logistics) the

cost of CO 2 transport is likely to be a secondary factor when selecting power station
sites. Also, existing power station sites are often likely to be retained for reasons of public acceptance.

• Transport of fuel (oil, oil products, coal) already represents a large proportion of total freight transport in industrialised countries. Introducing CCS on a large scale would considerably increase transport volumes

- to supply additional coal and remove CO 2 . There would also be a risk of pipeline or shipping accidents. although the risk per ship or kilometre of pipeline is relatively small.



### (02 Storage: Methods and Capacity

• For various reasons the storage possibilities for CO 2 are limited, both globally and nationally. Owing to the many uncertainties involved, current estimates of actual storage potential vary enormously. Global estimates show that although the potential is certainly considerable, in the long term it will certainly not be possible to solve the climate problem through CO 2 storage alone.

• Ecological, economic and capacity considerations mean that the only option e, g. for Germany is geological storage in empty gas fields and deep aqUifers. Taking into consideration only the country's major point sources and factoring in an average increase in energy

use for CCS of 30 %. the static range in Germany is between thirty and sixty years.

• Guaranteeing very low leakage rates is essential for the acceptance of underground storage. Corresponding evidence 

### will have to be provided in a comprehensible form.

• Little is yet known about the behaviour of CO 2 in underground reservoirs. Research projects already under way should greatly improve knowledge of drilling and injection methods, distribution of gases in reservoirs and monitoring methods.

Working Group WI. DLR. Z5W. PIK

### Summary ofTheses

Comparative Ufe Cycle Assessments

• From a holistic perspecti\'c the terms**zero~carbon, zero~emissions**  

### and COr 

### free are**mis~** 

### leading regarding fnssil fuelled electricity generation and hydrogen production. When the supply chain is taken into consideration and the usual assumptions are made about
CO 2 

### capture rates at the power station (88 % for post-combustion and**pre~combusti()n)** the potential for net CO 2 reduction is found to be between 72 % and 78 %, If the full range 

### of greenhouse gases is included, the reduction compared with a power station without CCS falls to a range of67 % to 78 %. Higher CO 2 capture rates of up to 99.5 % (achievable 

### with the oxyfuel process) allow in a coal-fired power station a net CO 2 

### reduction of90 % 

### and a net greenhouse gas reduction of78 %.



### o Tn this context it 

### is more correct Lo speak of low-C0 2 

### or**low~carboH** 

### electricity generation. 

### The CO 2 

### emissions 

### from the 'best' fossil·fuelled power station from the climate**protec~** 

### tiol1 perspective (natural 

### gas combined 

### <:ycle, NGCC) are 

### 'only' 50 % 

### higher than those from the 'worst' CCS power station (coal·fired thermal power station with**post~combus** 

### tioo capture).

.. The increased fuel consumption 

### involved in CO 2 

### capture and storage always 

### leads to a proportional worsening of the 

### outcome in the 

### other impact categories. There are, however, exceptions: with 

### post-combustion capture 

### other emissions are reduced 

### through 

### reaction with the 

### solvent acidification 

### falls by 

### 10 % 

### and PMIO equivalents (particulate matter) increase by 

### only about 2 %. 

### On the other hand, eutrophication increases by 

### 36 % 

### and

summer smog by 

### 94 %, 

### and demand for cooling water increases by 

### up to SO %**(post·com~** 

### bustlon).

o In comparison with CCS power stations, comparable**large~scale** 

### renewable energy**t>ys~** 

### terns (e.g. solar thermal power stations, oft-shore 

### wind farms) fare considerably better in aU impact categories across all stages of the process. Innovative fossil-fuelled power**sta~** 

### tion solutions like 

### natural gas 

### combined cycle (NGCC) 

### including ht'at extraction and combined heat and 

### power plant units (CHP) available today 

### are comparably environ

### mentally friendly as CCS plant are expected to be 

### in 2020.



### Other Ecoiogkal Assessment Factors for ((5

• As well as direct and indirect effects on the appearance of the landscape (e.g. caused by 

### increased fuel consumption) and the negative consequences of increased transport volumes (of CO 2 

### and additional fuel), the greatest other ecological impact would be the 

### potential unplanned release of stored CO 2 

### and the direct influence of the stored CO 2 

### on the immediate vicinity of the sink over the course of time.



### • 'D1e different 

### CO 2 

### storage options differ from one another

- sometimes conSiderably

- in
terms 

### of ecological and safety considerations. Geological sinks (e.g. saline aquifers) are considered to have 

### comparatively high**long~term** 

### stability, but there is still great**uncer~** 

### tainty concerning the underground movement ofCO 

### z and the resulting consequences.

" Regarding CO 2 

### storage in oceans its impact on marine ecosystems is still largely unresearched, but the 

### expectable risks are so great that most countries rule out even conduct· 

### ing further research 

### into this storage option.



### Economic Comparison of «5 and Renewable Energy Technologies

" In terms of electricity generation costs, a general structural difference must be noted when comparing CCS 

### and rcnewables. Large or very large cost degression and learning 

### effects arc still 

### to be expected in 

### both fields, but in the case of CCS these 

### will be counter· acted by further rises in fuel 

### prices. This effect is particularly 

### strong in the case 

### of gas· fired CCS 

### power stations.

RECCS PrOj('C1 

### 5

### 6 Summary otrheses

If) 

### It can be assumed that electricity from renewable energies will become economically competitive Lo**fossil~fuel** 

### based electricity earlier 

### with the introduction ofCCS. By 2020



### - the earliest point at which CCS technologies are likely to be commerdally viable

- a whole range of renewable energy technologies is 

### likely to be able to supply electricity at


### cost conditions comparable to or better than fossil-fuelled power stations. In the longer term, renewables can be eX"'Pccted to have considerable cost advantages due to their independence from fuel price fluctuations.

• The relative profitability ofeeS and renewables is currently still subject to many uncer

### tainty factors. The aforementioned predictions for renewables afe 

### based on assumptions of dynamic market development on a global scale, allowing very substantial cost dcgrcssion effects to be exploited through mass 

### production and learning curve effects.



### • When it comes to hydrogen, production using 

### renewables cannot be 

### expected to become competitive 

### with production using fossil fuels (including 

### CCS) in 

### the foreseeable future, 'Whether 

### or not 

### this is 

### the case, 

### hydrogen is 

### unlikely to become an important 

### factor in 

### the energy economy for several decades due to its generally high costs and the considera· ble infrastructure challenges associated with 

### its introduction. But 

### in principle this option represents an interesting strategic element for the transport sector

- today still largely dependent on oil- and could 

### potentially supplement biofuels 

### as a 

### diversifying element.



### The Role of ((S 

### in Industrialised (ountries: the Example of the German Energy Supply System

• The energy systems 

### of industrialised countries are characterised by a number of shared features, Firstly. there is great potential for energy efficiency measures. on both the supply 

### and demand sides. Secondly, 

### the growth 

### in 

### energy consumption, 

### and consequently 

### in energy-related greenhouse gas emissions, is in general much slower than in developing countries. The special case for Germany is that it 

### faces the complex challenge of having


### to replace 

### a large proportion of its 

### power station capacity within the 

### coming fifteen years. The 

### following theses are formulated for Germany, but 

### are also applicable to 

### other industrialised countries:

• As the main element of a climate protection strategy (the CCSMAX scenario) CCS runs into structural and capacity limits, 

### The earliest date when 

### CCS technologies are expected
to be ready for 

### implementation is 2020, 

### which is too 

### late for 

### the first wave 

### of the necessary power station replacements, 

### which has just begun. It 

### would necessitate extremely 

### rapid growth rales for CCS plant between 2020 and 2050 and speedy establishment of a hydrogen infrastructure.

• If a 

### vigorous political course of promoting renewables and efficiency improvements is 

### pursued over 

### the next ten to fifteen years, the realisation 

### of energy-saving potential and the successive expansion of renewables would be able to make a more rapid contribution
to climate protection than CCS. 

### IncreaSing energy productivity makes sense 

### in purely 

### economic terms, too. Hoth strategy elements are also associated with strong innovative stimuli for taking 

### a share of growing global 

### markets. Considerable increases in effiCiency 

### and the further expansion of l'cnewables are absolute preconditions for effective climate protection, If a sustained high tate of implementation is maintained, as described in the NaturschutzPlus (NATP) scenario) the use of CCS technologies is not absolutely necessary ttlf 

### meeting even ambitious climate protection targets. The slrategy outlined 

### in NATP is the best for the economy as a whole in the medium to long term, and should therefore be an aim of energy policy.

Working Group IV', DLR, l1W, PIK

### Summary 

### 01 Theses

• The period until 2020 should be used to thoroughly explore the development and**cost~** 

### cutting potentials of CCS technologies and to demonstrate the technological feasibilIty. If that process proves successful, CCS would offer the possibility, as described in the BRIDGE scenario, of swib.:hing to a**diO)ate~friendly** path even jf it has not proved possible to sustain the ambitious pace of implementation of efficiency potentials and renewabIes 

### over time. In view of 

### the real intereslS involved in the field of energy, especially in 

### the global context (where energy saving efforts are counteracted 

### by substantial growth trends), this constellation may well become reality.

• The successive introduclion of CCS after 2020 (presuming the 

### availability of 

### suitable sinks with long-term stability) tan act as an ancillary element helping to make it 

### easier

to maintain 

### the**~ustaincd** 

### efforts that 

### will be required to further improve efficiency and expand renewabJes. 

### In this situation CCS can attain 

### significant importance in fulfilling a 

### bridging function to 

### the establishment of a 

### renewable energy 

### economy. Consequently, it would 

### appear that further development efforts 

### for CCS 

### are necessary and in the**interna~** tiona I 

### context of 

### dirnate protection indeed unavoidable. 

### But this 

### must not occur at 

### the

expense of R&D 

### efforts in the field of efficiency 

### and renewables.

.. Overall it 

### must be 

### ensured that measures 

### for establishing a CCS 

### infrastructure are compatible 

### with the further expansion 

### of renewables and that permanent structural**ci)mmit~** ment.s and use conflicts (for 

### example with geothermal energy or decentralised CHP) are 

### avoided.

• If CCS is included as a 

### climate protection 

### element, upcoming power station planning
processes must 

### already begin considering the possibility of 

### future impicmentation of CCS. The idea of designing new builds 

### 'capture ready' is central here, and 

### is reinforced by 

### discussions at the EU 

### level about 

### possibly making 

### 'capture ready' 

### status obligatory for all



### new power stations in the 

### medium term.



### ((5 in the International Context

o 

### Above all at lhe global level CCS 

### could, from today's perspective, make 

### a noticeable CO\1w 

### tribution to meeting 

### ambitious. climate protection goals 

### alongside renewables and energy efficiency. 

### Under plausible assumptions CCS 

### could also help to 

### reduce the 

### economic costs of climate proteclion 

### if today's 

### e.xpectatiol1s about its technological development (espe· c1ally the 

### cost-cutting possibilities) prove to 

### be realistic. Including CCS in 

### an integrated overall concept seems lo be one option to stabilise the CO 2 

### concentration in the atmos+ phere at 

### 450 ppm with an acceptable level ofloss of 

### economic growth. This applies in particular 

### if the 

### alternative investment required in 

### measures to adapt 

### to the looming climate change is taken into account.

• Internationally too, CCS 

### can fulfil a 'bridging function' to an**emission~free** 

### energy**sys~** tern, 

### but only 

### if the 

### technologies arc available in time for large-scale implementation and the 

### costs of fossil fuels do 

### not rise too steeply.

• The largew::,cale 

### introduction ofCCS presupposes 

### that an institutional framework will be 

### established (preferably at the international level) 

### to sensibly regulate responsibility for the risks stemming from 

### CCS (giving consideration to the rrecautionary 

### and polluter 

### pays principles) 

### and offer involved parties an incentive to 

### guarantee the safety 

### of !:itorage.

• Plausible proposals already exist for the shape of such an institutional framework (e,g. carbon sequestration bonds), that could be integrated in the existing climate protec

### tion regime and via market mechanIsms involve the public in decisions about the use of**ccs~**

RECCI Pro!", 

### 7

### 8 

### SummaryafTheses

• Further research

- and also political decisions

- are required conct'rning the develop
### ment and discussion of the institutional framework, especially integration in the mechanisms of the UN Fra.mework Convention on Climate Change, the development of liability mechanisms and the implementation of legal provisions to restrict local risks associated with CCS.

• In upcoming climate protection negotiations CCS could improve the chances of persuad

### ing more states (e.g, United States, China) to undertake firm obligations on emissions, because it would allow them to retain their 

### familiar structures and their domestic pri
### mary energy base.

• Ultimately, for reasons of capacity (limited storage potential and finite fossil energy 

### resources), CCS cannot obviate the global need for further expansion of renewables and

a considerable increase in energy efficiency. But under particular conditions CCS can help in 

### meeting ambitious 

### climate protection targets while at 

### the same time extending the 

### time available for the necessary restructuring of the energy system.

Working Group WI, DLR, ZSw. PIK

# Summary

Ba(kground and Introduction

In recent years the discussion about carbon capture and storage (CCS) ha& moved steadily up the agenda in marty countries as well as globally in the context of meeting climate protection targets even more so as oil and gOiS prices have risen sharply and the increasingly urgent debate over security of energy supplies has

swung towards greater LIse of coal.

Carbon capture and storage technologies are not fundamentallf new. Some of them are already used on an industrial scale and fmds commercial application in oil extraction (enhanced oil recovery to increase the extraction rate of oil fields) or for conditioning natural gas (separating off the accompanying CO 2 ), However, for the. much larger volumes that w01.lld**gener~** ally 

### be involved in application in power stations or for centralised hydrogen production numerous questions still remain unanswered. That also applies to the field 

### of transport, to the pos5ible configurations 

### of a 

### CO 2 infrastructure and to storage. Demonstration projects (e.g. in Germany: 30 MW th pilot plant using the oxyfuel
process, planned slart 

### of operation 2008) and the first semi-commercial test facilities (the German company RWE Power AG plans to construct a coal-fired power !>tation with integrated gasification) CO 2 capture and storage with a net output of360 MW d by 2014) aim to achieve significant progress in developing the**technolo~** gies at the scale required for power stations.

Studies so far conducted in this field have concentrated largely on the technical feasibility of carbon capture and storage. There has not yet been a detailed investigation of the ecological, economic and sodallmpact across all stages of the process (e.g, energy balance, cumulative
energy demand, environmental impacl, resource con" sumption, risks and costs) of the kind that is today a matter of course for other new energy technologies, in particular renewable enery technologies. Only after such a study has been completed 

### will it be possible to decide how environmentally benefidal the CCS option really is, what its benefits and drawbacks are compared

to renewables and what contribution it can make to It sustainable economic structure, Including carbon**Lap~** ture and storage in the fossil fuel cycle makes it possible for the first time to conduct a comparison with**renew~** abies on equal terms (with re'pect to climate policy). Such a comparison, made on the basis of a comprehensive set of criteria, is the main objcct of the present study,**answ~rillg** the following questions:

RECCS PrOject 

### 9

• "'hat arc the conceivable paths fol' carbon capture and storage (technologies, infrastructures) and how do they 

### fit on the lime axis (development perlods)?

• How 

### do the LCAs 

### of these processcslook, and how does**low~COz** fossil electricity generation compare with CO 2 -free options (especially rencwables) in
this respect?

" What role can carbon capture and storage play for climate protection in comparison with other relevant options, and when (systematic comparison on the basis of significant criteria such as 

### cost, window of opportunity, ecological rest riel l{)nS, etc.)?

• What role can carbon capture and storage play at the national 

### and international1cvels as 

### a possible bridge to 

### a renewable energy system?



### Driving For(es and the Attitudes of Relevant Groups towards Carbon Capture and Storage

Several ditferent motivations are central to the development 

### of technologies for capturing, transporting and storing CO 2 , Alongside climate protection as the overriding motivation, questions of security of supply, technological aspects, and in some cases also very real commercial considerations (e.g. measures in the field of enhanced oil recovery in countries with a CO 2 tax such 

### as Norway) playa decisive 

### role. Technology that

can generate progress in international dimate protection negotiations is of particular importance, Among the supporters of CCS are

- above all**~** those states that have so far adopted a rejectionist or**wait~and-see** stance in the international climate protection process, such

as the United States. "The United States has also made CCS a central priority of the Asian Pacific Partnership (APP), a more**technology~oriented** climate protection agreement that represents a counterpole to the Kyoto Protocol.

Not least for these reasons, carbon capture and storage has become the subject of a broad range of networks at 

### the international 

### level, such as the Carbon**Sequestra~** tion Leadership Forum (CSLF), which 

### was initiated by the 

### United States in 2003.

### 10

The attitudes of actors in society towards CCS differ rather widely. Across the 'i",orld environmental and

nature conservation NGOs (non-governmental organisations)

- with very few exceptions

- agree on the**fol~** lowing points and demands concerning CCS:

• CO 2 must not he stored in ecosystems (namely, oceans),

• Long-term stability of storage systems must be demonstrably proven and guaranteed,

lIP Development of CCS must not be at the expense of R&D funding for renewahles, and

• Renewable energy sources and more rational usc of energy are preferable to CO 2 storage, and their implementation should be stepped up.

That is as far as the consensuS extends interna.tionally. German NGOs, for example, are generally at the more sceptical end of the international spectrum in their attitudes to CO 2 storage.

Political parties, too, differ in their positions on the technology. In Germany, for example, they range from the expectation that low·CO z fossil·fuelled power stations 

### will represent 'an important pillar' of energy pol· icy (the conservative CDU) to the call fOl' a coordinated
research campaign (the social democratic SPD) or clear rejec:tion (the left-wing Die Linke).

The positions of the different German ministries and expert committees can be summarised as follows: The Federal Ministry of Economics (BMWi) is supporting carbon capture and storage through the COORETEC research programme. This**wide~ranging** research**pro~** gramme is designed to allow the proce&s of replacing and expanding capacity in the**fossil~fuelled** power sector that 

### will begin around 2010 to be conducted at a high technological standard. The Federal Ministry for the Environrnc:lt, Nature Conservation and Nuclear Safety (BMU) and the Federal Environment Agency 

### CUBA) believe that there are still many unanswered questions to be resolved before CCS can be regarded as

a safe long· term option that is acceptable in social, e(:o· logical and economic terms. In a comprehensive**inves~** tigalion the UBA has examined carbon capture and storage in terms of sustainability criteria, and has come
to the conclusion that CCS is a set of non-sustainable technologies that can at best represent a transitional solution.

In its position paper the Council for Sustainable**Devel~** opmeot 

### calls carbon capture and storage a potentially important bridge 'to the era of renewable energy**sup~** plies'. To this end, it believes, CO 2 capture technologies should be integrated in highly efficient power stations, but only from the point of view of economic: efficiency. 

### The German government's Advisory Coundl on Global Change (WBGU) has taken a firm stance in favour of storing carbon dioxide, referring in this connection to

an 'end-of-pipe technology' that can make a contribu· 

## Summary

tion to climate protection fOf a limited period of time.
It fejects the storage options in ocean -waters (ccologicaJ reservations and missing long-term effect), biomass (lack of potential for expansion) and saline aquifers (no guarantee of safety and**long~tef[rt** storage). Ex:hausted oil and gas fields could be used temporarily, but only if a sufficient retention period can be**guaran~** teed. In terms of storage period, the WBGU has called for secure sequestration for at least 10,000 years. The 

### WBGU believes storage under the seabed to be permissible 

### only under certain conditions. The Advisory 

### Council on the Environment 

### (SRU) believes tbat car· bon capture and storage may be too expensive in comparison with other CO 2 avoidance options, and that the technologies may also come too late for the upcoming expansion and replacement of power station capac:ity.

Industrial Associations are definitely positive about CCS as a**long~term** option, but often prioritise improving the efficiency of the power station process as a con**~** tribution to climate protection. Capture of CO 2 , as previously mentioned, already offers opportunities for the oil and gas industry today.



### (0, Capture Methods

This investigation of carbon capture and storage in the

use of fossil fuels has restricted itself to the field of electricity generation in power stations and the potential future production 

### of hydrogen by means 

### of coal**gas~** ification

- in othe-r words to plants emitting particularly large amounts 

### of COz centrally (point sources). 

### In

terms of reducing CO 2 emitted through the use of fossil fueLIi, efficiency-improving technologies have previously been the main focus of attention. Applying these technologies quickly oyer the past decades has achieved



### a continuous in(rease in power station efficiency (despite stricter environmental regulations that have in

some cases led to increased fuel requirement). The efficiency levels achievable today are 43 % for**Iign[te~fired** power stations and 46 % for coal-fired power stations, while 

### for gas-fired power stations 58 % efficiency is now possible. For reasons of thermodynamics and materials technology this trend cannot continue forever, So



### a further significant reduction in CO 2 emissions from fossil electricity generation 

### will require the application of CO, capture techniques (which are largely already
known today) or a move to innovative new power**sta~** tion technologies that include CO 2 capture (e.g.**chemi~** callo(lping combustion).

CO 2 capture technologies arc more likely to become available in the medium term**(Iarge~scale** application is unlikely to occur before 2020) while the development of new, innovative power station concepts should be regarded more as a**long~term** option (see fig. I). Disadvantageous for CO 2 capture is the high energy requirement for the capture process itself, which leads

to significant reductions in efficiency (in some cases 10 percentage points and more) and significantly reduces

Working Group WI, DLR. ZSW, PIK.

### Summary**Mtl&$ure~** and gl)als**for(~** reduction In the power genflltCitlon sector

ShOrNerm:

• Effidmy Irl(f€ases

• (Ol gptufIl from flue g.)s

Medillf11"unn :

•**tmnhu~tiof1** wim**oxyg~n (O~yfuel)**  'Impr(l'(edairsepal'l1tiol'l

• IGC( with COshift and gas separation v.;lh COl absorberor "h membrane

• Olmhustion with**~'-C01** and components for CO, working**prO(e~**

> lon9"term :

. Newptlwerstabon concepts with pwtess-integrated o.'<ygco**luppl~ sy~erns** 

.**(~capture** wlthoutadditional energy reQuirement



### Fig. 1: Measures and goals for COl reduction in the power generation


### sector

the levels of efficiency achieved today (roughly to the level of twenty or thirty years ago). This means that CO 2 capture would lead to a significant increase in electricity generating costs and cause a considerable increase
in fuel consumption, the logistics of which must also be taken into account. For power stations constructed around 2020, estimates of the cost of CO 2 capture at the
power station (which dominates the additional costs of carbon capture and storage) currently vary between €30 and €60/t CO 2 • Various research, demonstration and pilot projects aim to Significantly reduce these costs, 

### with the goal 

### of bringing 

### the overall cost of the 

### whole 

## ces process (including transport and storage) down below €20/t CO 2 ,

From today's (technology) perspective there are three relevant options for 

### CO 2 capture in the short to medium

term (see Fig. 2). Flue gas scrubbing will probably be

an adequate option for retrofitting, especially jf it turns
out to 

### be possible to reduce the energy required still further through new scrubbing agents. Implementing integrated coal gasification 

## (ICee) would require much grealer availability, which is not yet adequate for the power station scale, The crudal point for the**oxy~** fucl proccss 

### will be to collect experience and**success~** fully put the lessons learned into practice (e.g, through the demonstralion project at Schwarze Pumpe in Germany, launched in 2006 by Vattenfall),

The method of capturing COl from flue gases in conventional power stations**(post~combustion** capture) is basically available today, but has not yet been**dem~** onstrated on a commercial power station scale. In the longer term this te<.:hnology is unlikely to become widely established unless its energy consumption can be reduced significantly,

RECCS PrOJect 

### 11**Pre~combustion** capture of CO 2 in**coal~** or**gas~fired** power stations ',ArJth integrated gasification combincd cycle (IGCC and natural gas combined cycle, NGCC) is from today's perspective a better method than flue
gas capture of CO,. Apart from its higher efficiency lev

### els, the prime advantage of this technology lies in its flexibility both in terms of 

### fuel (coal, biomass, substitute fuels) and in terms of product (electricity, hydrogen. synthetic 

### gas and liquid fuel). The next step here is**large~scale** technical demonstration. The 

### IGee**tech~** nology itself

- without CO 2 capture

- has already been tested in several plants (e.g. Buggenum in the Netherlands and Puerto llano in Spain), Before CO 2 capture is implemented there will be a need for improvement and development "findividual components (e.g. hydrogen turbines}, In Germany RWE Power intends to take the first step towards implementing this technology by building a full-scale rGCC power station with CO 2 capture (output (450 MW**gm~** I 360 MW",) by 2014.

The 

### oxyfuel process (combustion in pure o:rygen) currently offers the best prospects for CO 2 capture in terms of achievable overall efficiency of the process (and also the resulting costs). because it is largely based on conventional power station components and technology.
It is not yet possible to provide a precise assessment because the process is still at the beginning of the dem, onstration pbase. At Schwane Pumpe in eastern**G(',"r~** many Vattenfall Europe is building the world's first pilot plant for lignite combustion u5lng the oxyfuel proc·

ess. The Vattenfall pilot plant, which has an output of
30 MW (thermal), will be used for research and development purposes with the aim of developing the new technology to the point where it is commercially via· ble. It is scheduled to begin operation in 2008 after a construction phase lasting about three years. Initially the CO 2 

### will not be stored, but corresponding concepts (e.g, transport options) are being investigated,

Whether CO 2 capture technologies become relevant for
power station replacement will depend on political and economic circumstances. The lack of incentives for retrofitting existing power stations with CO 2 capture has

meant that this option has not been relevant to date. In
order to be prepared for future developmenls it might make sense to build new power stations 'capture ready' (prepared for retrofitting with CO 2 capture). That dis· cussion is already under way,

'Ihe space required for the additional components can place restrictions on the implementation of CO 2 capture and storage. Connection to suitable storage and transport infrostructul'es is also a significant location faclor,

### 12

C02 

### capture processes

1) Post·combusdoD

2)0.)'1,,1

3] Pre·combu5tion

fig. I: Methodl of CO, capture at the power It'tion



### (0, Transport Methods

Because of the considerable transport volumes that

occur with CCS, the main issue when analysing**loca~** tions for sources and sinks is to reduce transport dis·

tances and costs. to a minimum. Case studies show that the spedfic transport costs can vary very**consid~** erably from case to case. Even 

### if the cost of transport 

### appears small in comparison with the cost of CO 2**cap~** ture at the power station, the aspect of cost efficiency of CCS-related transport 

### will have to be induded when 

### selecting locations for new sources,

Alongside transport distance, the question of the**gen~** eral accessibility of the various transport infrastructures that are suitable for CCS is an initial parameter for location analysis. Wherever it is possible to use existing bulk-capable means oftransport and transshipment
facilities there will be potential for reducing transport costs,

From the energy efficiency, economic and ecological perspectives the only relevant options for large-scale
CO 2 transport are pipelines (onshore and possibly offshore) and large tanker ships (depending on the location conditions barges or seagoing vessels for offshore storage). 'Ihe ad\'antage of the pipeline is that it can transport very large quantities of CO 2 without interruption at relatively acceptable environmental and financial cost But constructing a CO 2 pipeline infrastructure would be a time-consuming process and
would tie up considerable capital; this would only 

### Summary

_ .. research required

appear reasonable for long-term usage (> 20 to 30 years). Ships, on the other hand, are more flexible and

more quickly available, but require intermediate storage facilities and loading/unloading infrastructure. With inland waterways the restrictions on availability during periods of low water levels must be taken
into (:onsideration, Transporting CO,! by road and rail tanker is 

### an option only for 

### small quantities 

### and will
therefore probably only be relevant for the demonstration and launch phase (see Table I).

The high investment 

### cosls involved make it especially important to coordinate the timing of planning, approval and construction of power stations, pipelines and CO, sinks. So establishing a CO, infrastructure
necessitates forward-looking planning and coordination between the different parties involved.

Unlike the case of pipeline transport, there has so far been practically no experience in transporting CO 2 by ship. However, because CO! has similar**ph~'sical** properties to LPG (liquefied petroleum gas), experi.



### coce with LPG transport 

### is partially 

### applicable to CO 2 transport.

Both 

### the aforementioned transport optiOn!; require gas conditioning 

### in order to transport the CO 2 in the densest possible form (liquid or super(ritical). Pipelines require conditioning to high pressure (approx. 80 to 120 bar), while tankers require very low temperatures
at ambient pressme (low-temperature tankers) or tem

### peratures below normal combined with pressure above normal (hybrid tankers).

WorKing Group WI, DLR, ZSW, PIK

## Summary

Modeof transport

< 

### to

< 100

< 1.2

< 0.5 MIla Seasonally**appro~.l re~trlcled**  (water**le~els)** Always dPprux.1.5 (function of diame1er)

Always**appro~.** 5**R~** .. tri(\ed in wln- appftlk 25 ter, congestIOn



### Both gas conditioning and CO 2 

### transport require quite a lot of energy, normally electricity for compression andl



### or (ooling. According to current knowledge the energy required for CO 2 

### compression is equivalent to an efficiency loss at the power station of about 2 percentage points (for gas-fired power stations) to 3.5 percentage pOints (for coal-fired power stations). This additional

energy requirement causes additional CO 2 emissions.
Estimates of additional (energy-related) 

### CO 2 emissions associated with CO 2 transport vary greatly, especially in relation to transport distance and capacity, Here addi· tiona I (energy-related) emissions of 1% 104 % per 1,000 km are expected for ship transport and 1 % to 2 % per 1,000 km for pipeline transport.



### The range of average cost estimates 

### for CO 2 transport by 

### pipeline or ship is between about €l and €lOlt**(depend~** ing on mode of transport, distance and capacity) and represents about a 10 % share of the overall costs of the
CCS proceSli (comprising capture, compression,**lrans~** port and storage). In relation to the other infrastructure**cost~** (electricity transmission, fuel logistics) the cost of 

### CO 2 transport is likely to be a secondary factor when selecting power station sites. Also, el(isting power sta

.. tion sites are often likely to be retained for reasons of public acceptance.

Already today. fuel (oil, oil products, coal) represents a large share of goods transport. Introducing 

### CCS on a large scale would increase freight volumes considerably, through the supply of additional coal to power stations 

### and the removal of CO,.

Safety statistics for existing CO 2 pipelines (in particular in the United States) show a smaller leakage risk than for pipelines carrying natural gas or hazardous substances; nonetheless, routes should avoid densely populated areas where possible for reasons of safety.

RECCS Projl:([ 50metimes

Will almost always have to be Wl'lstructed from scratch (largely**inve~tmf01)** Gerltrally

Always B.arges not seagoing,
time rrslri(\Jons

25 year operating period, hlgher{osts in built,upJreal

NOrse

((lst, noise and emissions, a((ept,mce,**tim~** rEstrictionl 

### 13

Tablet: 

### Characteristics and suitability 

### of differenl modes of transport for CO, transport

In populated areas safety measures against leakage and overpressure are required. Although the relative risk associated with ship transport is also predictable, large-scale introduction of 

### CO 2 tankers for 

### CCS would
increase lhe absolute risk of shipping collisiuns and tanker accidents.



### co, Storage Methods and 

### Capacity

There are various different ways to withdraw COt from
the atmosphere. A distinction must be made between
utilisation for technical 

### and chemical purposes (e,g. producing carbonic acid, dry ice and feedstock for**poJ~** ymer chemistry), storage in geological formations (e.g. saline aquifers), sequestering CO 2 in 

### the marine environment either directly (e,g. depositing it in the ocean depths) or indirectly (e.g. algae formation) and with· drawing**CO~** from the atmosphere by intentionally gl'Owing biomass (e.g. forestation). A mineralisation

process fol' binding CO 2 to silicates is also under dis· cllssion (especially in the United States) but it 15 still in
the early stages of development and is associated wilh


### vcry high energy requirement and very large amounts of material to be disposed of. Fig. 3 shows an overvie'",' of storage projects currently under way across the 

### worfd.

For various reasons the storage possibilities for CO 2

are restricted at both the national and global levels. The

many W1certainty factors lead to it very wide range of 

### estimates about the 

### extent of existing capacity, and the

same 

### applies to the question of the fundamental**suita~** bility of the various storage options, where ultimately a**case~by·case** analysis will be required to obtflin**prfl.cti~** caUy relevant resulls.

### 14

CO, storage projects operating**wo~dwlde**

50 add gas injection facilities In North America

• ECBM· project

Q £OR

.... project

• Gas production held

o Saline**aqutf~r**

.. EnhMcffl (oal Bed Methane

( :::: deep (Qat seam;)

*10 Enhanced Oil RwV'!!y

fig.3: (0

, 

### storage project. operating woridwide (lEA database)

Estimates made in 2004 put global storage potential in the range between 476 and 5,880 Gt CO 2 (with a prob· able potential 0' 1,660 Gt CO,). By comparison, global
CO 2 emissions i:l2005 were 27.3 

## Gteo z ' This shows that the potential of CCS is certainly considerable but that regardless of other factors, the limited storage capacity alone means that it 

### will not be Fossible to achieve a**last~** ing ,olution to the climate problem through CCS. Table
2 shows the storage capacity and a selection of assessment criteria, for the example of Germany.

According to currcnt information the theoretical storage potential in Germany is between 19 and 48 Gt CO 2 , The largest and

- in view of the numerous as yet unrcsolved issues affecting storage in deep coal seams (e.g. concerning permeability)

- most important share**relate~** to deep saline aquifers, supplemented 

### by the more limited possibilitie5 for storage in depleted gas fields. A calculation focusir.g on these two storage options and taking into account an average extra energy requirement for CCS of30 % comes up with a static range of between thirty and sixty years for CO 2 point emission sources in Germany (2005: 393 

### Mt/a).'

In principle the storage of CO, in geological structures

can draw on many methods and technological 

### procTaken together**Ihe~e** two storage options have a potential of 143

to 30.5 Gt CO 2 

## Summary

esses currently in usc in the oil and gas industry and in the disposal of liquid wastes, However, drilling and injection methods, computer simulations of the distriimtion of gas in reservoirs and monitoring methods 

### will have to be adapted to the special requirements of CO 2 storage. Here there is still a great need for researcb and development. In 

### Germany the Ell·funded C02SINK project will significantly increase knowledge about the behaviour and controllability of CO 2 in underground reservoirs.



### Criteria for a Systematic ASSl!ssment of CCS

A systematic comparison 

### of various 

## ces technologies with other technology options such as energy efficiency and renewahles requires 

### a comprehensive catalogue 

### of criteria. The criteria used here can be categorised as**fol~** lows:

Ecological criteria

• Environmental impact as per life cyde assessment (LCA)

• Energetic efficiem:y

• Other ecological impacts, ecological restrictions,
consequences and risks (direct and indirect)

Working Group WI, DLR. ZSW, PIK

## Summary

Peep (oaheams +(+) 3.7-16.7

Depleted oil fields



### I 0,11

5.lltci'lverns
0.04

Disused coal mines + 0.78 +

+ ++ ++

k. A. + + 

### lS

Table 2: 

### Assessmenl of geological storage options 

### in Germany using selected criteria

(OSI**~sllmale(Qnt3ins** only storage <osts without capture, compression ¢r transport (i1fter HOFYS 2004, BGR, authors' additions)

Figuresafter May**~1** ai, (2005)

Criteria:**Nf'9dtl~e** or**~ry** probktnJti(

-**Futld{\m~ntal** dlfflOJlucs still eXist, but may be msolvQble

+ G()od.**orf~w** obmdes

+ + Vrrygond**Parenthese~** mdK.3te unccrraimies or places where each individual ca5pwill have to be assessed

Economic criteria

• Generation costs and CO 2 avoidance costs (specific investment costs, resulting electricity and hydrogen production costs)

Other criteria

• Timeframe for application (possible time of implementation) and market readiness and/or R&D still required

• Compatibility with power plant replacement needs

• Acceptance

• Compatibility with existing structure and possible future development trajectories

• (Technological) stimuli for global climate protec
Lion

• Industrial policy opportunities

.. Transferability to developing countries (not appli· cable for Germany)

., Compatibility with other climate protection strate· gies (decentralised options)

• Impact on import dependency

• Security policy implications

RlCCS PrOject 

### Comparative Life Cycle Assessments

For the ecological c\'aiuation of selected system configurations (process chains from natural gas and coal to low· CO 2 electricity and hydrogen) the life cycle assessment method (LCA) defined by ISO 14.040ff was used. 

### This integrative approach analyses the material and
energy flows required to produce a kilowatt· hour of electricity or hydrogen and calculates their**environ~** mental impact.

For 

### eiectricit)' gencmtion the environmental impact of the following fossil fuel conversion paths were lnves, tigated; post-combustion (with coal- and lignite-fired thermal power plant and natural gas CC), pre·combustion (coal-fired IGCC) and oxyfuel (with coal). TI,e Ruhr region (a densely populated industrial region in western Germany) was selected as the location of the power stations and an empty gas field 300 km away in northern Germany as the sink. For purposes of comparison with renewable energy paths, electricity**gencrah~d** 

### by solar thermal power stations (in Algeria) and by

, ... ind power (in the German North Sea) was also modelled. In order

to have the same reference location as with the fossil· fuelled options, the electricity was assumed to be transported to the Ruhr region using bigh·voltage DC lines. The following central conclusions can be drawn:

### 16 

## Summary

9 COl"eql Coal-fired PP

kWhel rif:49%-> 40%138% lIgnile-firoo PP eff:41S%-::d4% Maturalgll$ (( eff:60%-> 51% Coal·fired IGee eff: 50%-> 42% VIlO

WI)

800

100

@
500

. 400,

300

100

100



### o
C\lill·fired (iJjl-flr1!d Coal-tired Lignitepp PP

... i1hCCS 0xyI'ue1 fifl'!dPP PPwhbCCS**l~oltHired** rpwlth«S NatUral galee Nal'\lralga! (CwhbC(S IG«( 16" wlthC(S 

### , "'! II Upstream

• Power Plant (PPI

: CI capture &**Liqu~fadio,** Ifill Transport

; Ii Storage



### Fig. 4: LCAs of 

## ees plant in comparison with selected renewables (here: greenhouse gasesl

The high rates of CO 2 reduction generallr cited in the
CCS discussion (capture rates of88 % and more) relates only to CO 2 emissions directly in power station**oper~** 

### atiofl. If we take a holistic approach, 5 % 

### of the CO 2 emissions already oo;::ur in the supply chain both with 

### coal-fired thermal power stations and with natural gas CC. Reduced efficiency also causes higher consumption 

### of primary 

### energy and thLis 

### a 'larger' coal 

### or natural gas supply chain, Taken together, these factors mean that 

### with a capture rate of 88 % 

### actual CO 2 

### emissions can
not be reduced by 88 %, but only by 72-78 %, In view of this 

### fact it 

### is unjustified 

### to speak 

### of**'C02~free'** 

### or**'zero~** 

### carbon' power stations. Even 

### if the capture rate at the
power station can be increased still further in future, 

### the designation**'JOW~C02'** 

### is more pertinent. 

### 2

The discussion to date has also neglected to consider that greenhouse gas emissions as a whole

- and not only CO 2 emissions have to be reduced, The Kyoto Protocol requires Germany, for example, to reduce a total of six 

### greenhouse gases (and not just CO,I 

### by 21 % 

### by 2012.lf the 

### effects of CO 2 capture on 

### greenhouse gas emissions

are calculated, it is found that the potential reduction is
less than proport:onaJ. For example, with a CO 2 capture
rate 

### of 88 % 

### (at the power plant) greenhouse gases as a 

### whole can only be reduced by 67-78 % 

### (see Fig. 4)3 The

reasons for this are again the considerably increased prirnar)' energy consumption a.nd the methane emis

M 

### sioos associated with fuel extraction 

### and transport, which can be relatively high depending on the fuel and 

### its source, Under the given assumptions 

### these have a

2 F'ot exumple, future capture**rate~** o{up to 99.5 % are expeded through the oxyfl.lcl process. for a coul" fired power statIOn this
would result in u net CO 2 reductIOn of 90 to.

3 Even with the oxyfuel method the net greenhouse gas reduction

for a coal· fired pov.'er station would not be greater than 78 % (desptte the hlghcr capture rate of99,5 %). disproportionately large impact on the greenhouse eflecl. Improvements in the supply chain (e.g. collecting and using mine gas) could strongly improve the results. From 

### a holistic perspective this lessens the reduction achievable through CCS power stations. With 396 g 

### CO 2 equivalent per 

### kWh the 'best' 

### power station 

### (in climate terms) without CCS (natural gas CC) has only
51 % more greenhouse gas emissions than the 'worst'

power station with CCS (coal-fired thermal power**sta~** 

### tion with 262 g 

### CO, equivalent pel" 

### kWh). Of all 

### the**fossil~fuelled** power stations considered, oxyfuel prOM duced 

### the best greenhouse gas results under the given 

### assumptions. Physical capture of almost 100 % 

### of the CO 2 allows 

### net rates 

### of reduction 

### of90 % for 

### CO 2 

### emissions and 78**(~h** for greenhouse gas emissions,

Fig. 5 shows this in comparison with selected technologies 

### from the field of 

### rencmbles, whose impact by contrast are very small (resulting from manufacturing of 

### the plantl.

Overall, CO 2 capture requires additional energy conM 

### sumption of20 to 44 %, depending on the process, The higher energy consumption is felt directly and proportionately in various 

### impacl categories in the LeA, 

### This applies, for example, to photo-oxidant formation, eutrophication, acidification of soil and water, and particle emissions (PMIO). On the other hand,**individ~** ual emissions 

### such as S02' N0 2 or dust are 

### reduced through reactions with the solvent, which in overall

terms causes .-1 reduction or at least a reduced increase

in individual impact categories. Pig. 6 shows this effect for the example of the modelled**lignite~fired** power sta

M bon**(post~combustion).**

The 44 % increased energy consumption initially causes


### a proportional increase in all impact categories. But overall the aforementioned influences 

### callse a reduction

Working Group WI. DLR. 11W. PIKSummary 

### 17

Fig" 5: 9 C0 2 "eq/kWh tl
1,000

900 

# }l BOO

700 CSP: Concentrating solar thermal power plant
«(: Combined (ycle Compari50n ofgreenhouse gas emissions from (C5


### power stations with selected plant from the fields of renewables and advanced fossil-fuelled CHP tech

### nologies 600 CHP: (ombinj!d he",t 3nd powr

500 0: Germany

400

100

10O

100

Coal/lignite Natural gas CC Wind!**Nfttural9a~** Natural Electrlcltymlxscenario5 wlthol,ll 

### «(5 with «(5 without ((S with (cs CSP COOP gas (UP 02050 EU 2fJ50



### of 3 % 

### in the acidification calegory, and PMIO equiv- .lients rise by 

### only 

### approx. 24 %; 

### on the other hand eutrophicalion rises by 40 % and photo-oxidant forma

### tion by 524 %"



### A comparative analysis, however, showed the**inves~** tigated renewable energy options to have considerably 

### better values than the fossil-fuelled power stations
with CO 2 capture. Even when electricity transmission is 

### included, the CO 2 

### emissions, greenhouse gases (sec Fig, 4) and cumulative 

### energy demand of solar 

### thermal electricity 

### and 

### electricity from wind 

### power is just 2103 % 

### of the corresponding 

### figures for 

### fossil·fuelled CCS pla.nt.

For hydrogen production tbe environmental impact of

steam reforming of 

### natural gas and coal 

### gasification



### were investigated, The Ruhr 

### region was 

### again sdC\.:ted 

### as (NaH) (2"{)



### the location. Renewable hydrogen production was**mod~** 

### cUed as electrolysis using 

### electricity from solar thermal
power stations in Algeria and 

### offshore wind farms in 

### the 

### North Sea (as modelled for electricity 

### generation). The location for electrolysis was 

### the Ruhr region; again**high~voltage** 

### DC lines were used for transmission. 

### TIle following central conclusions can be 

### drawn:

As with the case of power stations, we cannot speak of 'C0 2 

### -free' production 

### of hydrogen, It would be more pertinent to use the term**'!OW~C02'** 

### hydrogen, When the supply chain is taken into account, even with a 

### caph turt' rate of 88 % (coal gasification) it would 

### only be 

### possible to reduce CO 2 

### emissions by 

### 81 %.

With natural 

### gas steam reforming, reduction rates of only 39/52 % (CO, 

### emissions, depending on different

III**U~stream** • Power plant (PPJ Cl Capture & liquefaction iii Trilmport 1m Storage Fig, 6: Comparison of other impact categories for lignite-fimd


### steam power station without and with CCS 

### (post

### combustion) 0.30

027

0.24

0.11

0.18

0.15

0,11

O,O!

0.06 Photo-oxidant formath;m Eutrophication Ig**fth~n,eqlkWheIJ** (g**POl:eqIkWh~IJ**

+524%

. Ml /"_ 0"00

.... ___ _ Addlfication PM1G-equiYlllents (urn. energy demand [10, 9**SOf~q/tWhelJ** [10· g PM10-fq/kWhejl [kJ·100,OOoJkWhtll

lignite·**llgnlt~·fired** lignite- lignite·fired lignite- Lignite-fired Lignite-**li9nil~·1ir¢d** lignite" Lignite-rued fired PP PP With ((S fired PP PP with CCS fjred PP**P~** With (5 fired PP PP with «S fired PP PP with CCS

REC(S PrOINt

### 18

reforming technologies) and 36/49 % (greenhouse gas emissions) are possible from today's perspective, if it is assumed that only the COl emissions from the**synthe~** sis gas can be captured at reasonable cost, and not those that occur beforehand when natural gas is burned to produce process heat.



### Other Ecological Assessment Factors for ((5

The systematic approach of the LeA does not cover
every ecological criterion. As well as direct and**indi~** reet influences on the landscape (e.g. through increased fuel usage) and tbe negative consequences of increased transport volume through the construction of a CO 2 infrastructure, the greatesl impact would result from the possibility of unplanned release of stored CO 2 and
the direct influence of the stored CO 2 on the**surround~** ings of the sink over the course of time.

The various storage options differ

- in some cases considerably

- in terms of ecological and safety aspects. The risk of leakage is present in all geological storage options. Whereas storage in exhausted oil and gas fields 

### and use in 

### oil production (enhanced 

### oil recovery, 

### EOR)
appear relatively safe for the population and the**envi~** ronment, injecting CO 2 into disused coal seams could
pose considerably greater risks. Saline aquifers are regarded as relatively stable long-term sinks, although there is still a great need for research into the underground movement of CO 2 (mechanisms of**di.ssemi~** nation and activity). Such aquifers have so far generally only been explored in the vicinity of hydrocarbon deposits so there is a shortage of comprehensive data and a.o;sessments of their petrophysical properties. The introduction of CO 2 leads to acidification of the water in the aquifer. Through its corrosive properties the acidic water codd cause changes to the surrounding

strata (especially carbonates) and to unprotected borehole seals.

The use of deep (currently uneconomic) coal seams bears the ecological risk of the extracted methane**escap~** irlg (methane is a considerably more potent greenhouse
gas than CO 

### z ' by a factor o(21),

Marine storage options are associated with very great uncertainties and risks, Direct cause and effect**rela~** tionships have so far only been demonstrated in certain cases, Acidification of seawater shifts the carbonate equilibrium: the shells of calcifying organisms become thinner and can even dissolve, interrupt. ing food chains or at least altering them with**ines~** timable consequences. CO 2 lakes on the ocean floor
affect more than the local ecosystems. 

### MallY aspects of the behaviour of the ocean floor

- submarine slides, undersea quakes, etc.

- may be understood, but they remain unpredictable. Fundamentally it must be noted that storage in the oceans would not lead to permanent sequestration of the CO 2 , Dissolving CO 2 in the ocean depths leads to delayed re-emission into the atmos

### Summary

phere after a few hundred years at the latest, when**oce~** ank circulation brings the water masses into contact with the atmosphere again. In view of the undarified

consequences of marine storage options they are categorically rejected by the environmental organisations and are being pursued in any form in only a very few countries (in particular Japan).

Fixing CO 2 in biomass by planting forests and grow

### ing mOl1ocultures brings with it multifarious ecological problems. It must also be emphasised that this form of storage is only a temporary one, with delayed rdease. ''\Then a period of several generations is considered, the reduction effect is nil. Additionally, monocultures displace other species and alter biotopes.



### The construction 

### and operation of renewable 

### energy technologies 

### e.g. constructing 

### wind farms, hydroelectric dams and solar thermal power stations

- can in
certain cases be associated with considerable ecologi"
cal consequences and disfiguration of the landscape.
Within a social and energy system guided by**sustain~** 

### ability principles, decisions would have to be made about which interventions are acceptable for the population and the natural environment and which should be avoided. vVhereas the impact of using reneVo.'ables is largely known and understood, decision-making with re<;pect to 

# ces is from today's perspective still**ham~** pered by numerous uncerlainties and open queslions,



### Economic Comparison of ((S and Renewables

If the capture and stomge of CO 2 emissions from**fos~ sil~fuelled**  power stations can be demonstrated successfully, electricity generating costs (at power station) of between 6.5 and 7 ct/kWh can be expected on the basis of CCS power stalions commercially available in 2020 (interest rate 10 %/a). In view of the fud price rises expecled in the longer term, a further rise in costs to between 7 ct/kWh (coal) and 8 Cl/kWh (natural gas) i, probable by 2040, In coal-fired power stations the fuel price effects could potentially be largely balanced out by further technical progress. Our calculations put CO 2 avoidance costs at between €35 and €50/t CO 2 in 2020, when the same power station without CCS is taken as the reference for comparison. Here coal-fired power stations are towards the bottom end of the range, gas-fired
towards the top. This is less than the cost range assumed today and assumes that significant learning processes 

### 'will already have occurred by then, but is still**signifi~** cantly higher than the costs of about €20/t CO 

### z that the
energy business is aiming at for the process as a whole.

Rcncwables, which on the basis of a representative mix

- today still involve electricity generating costs of

approx. 13 to 14 ct/kWh (again assuming inlerest rate 10 %/a) can also achieve that level of cost, 

### by 2020 if their market introduction continues at a similar pace to now. With a continuing global increase in market penetration and learning effects significant cost**degres~**

Working Group WI. DLR, ZSW, PIK

### Summary 

### 19

Electridty generating (osts In (tlkWh
DLR 100S price forecast with CO, penalty; Interest rate 10%/a**14,-----~~------------------------------------------------------,**

11 (jp Coal·fired I(iCC with 

## ces

o (oat-firedstfJam turbine without «S
1i& Naturill Gas 

### « with (eS Nallllilt Gas ( without (es

• Natural Gas CC without «S (EWI2005) 

## ,01r---------'---

..**----~~------------------------~O~C~'~al.~fir=.d~st~ea=m~1U~rb~in~'w=i1~ho~uf.lc7.cs~IE"WWll~OO"5"1**
Wind offshore



# .......... ,

o -J------'------"r"'-----"--

___ ,--

____ .J......

____ ,--

____ .J......

____ ,.-

___ -'--

__ 

### -I

2000 2010 2020 1030 1040 1050



### Fig, 7: Development of electricity generation costs (for new plant) for renewablel, conventional gas· and coal· fired power stations and eCI 

### power stations, fuel prices after "OLR 2005" and foreonventlonal power stallons without 

## ces after EWI lOOl given for comparison

sions can still be expected for renewables in future, so that by 2050 the level of costs for generating electricity 

### from renewables in the characteristic mix under COllw sideration could fall to 6 ct/kWh, Individual technolo

### gies could achieve electricity costs 

### of approx. 4 ct/kWh 

### if 

### a continuing expansion of global markets allows 

### the learning wrv!;' 

### to continue to be exploited (see Fig. 7).

If the pace of expansion of rcnewables in the electricity se(tor remains fast

- as in the various scenarios that describe a switch to a climate-friendly energy supply based on a combinution of stepping up the expansion of renewables and energy efficiency (e.g. the Naturschut· zpJus scenario)

- at the time when the first CCS power stations might be coming on Slream 

### some technologies (e,g, wind offshore) could already be offering cheaper electricity generation costs and further increase that advantage over the course of time. Here significant
cost·redtJClion 

### effects come through the global market effects, so even jf 

### renewables in Germany were to grow less dynamically, cost parity between CCS and individual rcnewables can 

### be expected. Only if 

### fuel price rises 

### '''''ere to be very small or cost reductions in the CCS
process were to surpass the foreseeable effects would the situation be more favourable for 

### CCS plant This would

not negate the general effect, but would push back the point on the time axis where**renewable~** 

### become relatively competitive.

Under the given assumptions there is neither a**compel~** 

### ling economic reason to give CCS tel:hnologies**pre(er~** 

### enc€' over a further expansion 

### of renewables for elecRECCS ProWl 

### trkity generation. Nor, though, do they**r~present** 

### a prohibitively expensive option and 

### if successfully commercialised under suitable conditions (inexpenoivc, stable long-term storage options, good infrastructure, cheap coal) could become part of the future electricity generating regime in some world 

### regions.

Tn an economic comparison of low-C0 2 

### and largely**C02~free** 

### options for hydrogen production (CCS 

### versus renewables) the fossil option comes off best. By 

### 2020 hydrogen from coal gasification with CO 2 

### capture will
cost approx, €1250/G/ (450 

### c,/kWh, upper heating value, at plant), or about twice the cost oftoday's hydrogen from natural gas reforming. Further fuel price rises until 2050 increase the cost to about € 14/GJ 

### (5.04 etl 

### kWh). Only electrolytic hydrogen via electricity from cheap hydropower 

### can compete 

### with this, but the available capacity is small. Only in the longer 

### term costs of around**€16~t8/GJ** 

### for electrolytic hydrogen from wind

or solar electricity can be expected; around 2020 the

cost will probably be about €19-20IGJ, In the medium
term the cost of generating hydrogen will always be at least double the cost of natural gas. So for economic rcasons hydrogen will not be implemented as a fuel before 2030, Regardless of the way it 

### is produced, it will proba· bly 

### be several decades 

### before hydrogen becomes**impor~** 

### tant in the energy sector in relevant quantities because of the considerable infrastructure challenges associated with its introduction.

### 20

The Role of (CS in Industrialised Countries

- the EKample ofthe German Energy Supply System

In this study three different scenarios were developed
for the future energy supply in Germany (as a representative industrialised country) in order to analyse the role of CCS in the energy sector in comparison to renewables. In all three scenarios energy-related CO 2 emissions were reduced to 240 million tla 

### by 2050, which corresponds to a reduction of about 75 % compared with 1990. The scenarios are based on the follow

### ing assumptions:

• CCSMAX: CCS as the main element of a climate protection strategy with 'maximum' use of CCS technologies within the framework of a development that otherwise largely follows current trends for energy consumption and expansion of renewabIes (relatively small mobilisation of efficiency potentials, limited implementation of the expansion potentials of renewables).

• NATP: Concentration on across-the-board exploitation of energy saving potentials and vigorous expansion of renewable energy technologies, as described in the 'NaturschutzPlus' scenarios prepared for the Federal Environment Ministry (after 

### BMU 2004 and BMU 2005). In this scenario CCS is

not required,

• BRIDGE: CCS as a bridge to further expansion of renewables while at the same time increasing energy efficiency and expanding renewabJes more strongly than in the reference case but less than in NATP. In this scenario the two strategy elements are insufficient to achieve the climate target unaided, so the

use of CCS is required.

Various key findings can be drawn from the scenario analyses. Emission-reducing measures in the field of electricity generation alone will simply not be enough

to meet tbe climate protection target. Similarly comprehensive measures in the heating and vehicle fuel sectors

are also required, As well as expanding renewables, the exploitation of efficiency potential will have to make a very considerable contribution. If greater use is made
of fossil resources, the alternative of generating hydrogen by gasifying coal with carbon capture and storage is always an option.

As the main element of a climate protection strategy CCS runs into structural and capaCity limits (CCSMAX scenario). The earliest date when CCS technologies are expected to be ready for implementation is 2020, which is too late for the first wave of the power station replacement needs, which has just begun. This scenario would necessitate extremely rapid growth rates for CCS plant 

### between 2020 and 2050 and speedy establishment of a hydrogen infrastructure. With 5,900 PJ/a the demand for coal in CCSMAX rises to three times today's level. By 2050 hydrogen would be the dominant form of


### energy, supplying 47 % 

### of final demand. The amount of 

### Summary

CO 2 to be captured and stored in 2050 would amount to 

### about 600 million t CO,/a (Fig. 8). At that level the storage capacity available in Germany would last for just

one or two decades. Cost advantages for energy**pro~** duced using CCS are either non-existent (for electricity) or marginal (for hydrogen) so there is no decisive economic incentive for such a prominent preference for CCS. The high level of funding already required today
in the form of R&D and demonstration plant for such a strong expansion of CCS technologies would probably demand a major turn away from support for efficiency strategies and strategies for expanding renewables. A great challenge in view of the 

### very many questions that

are still open is that the lead times involved mean that it would be necessary relatively qUickly to achieve a very high level of certainty about the ecological impact and long-term stability of the potential CO 2 sinks.

A climate protection strategy following the NATP see· nario, which manages without CCS, would not yet develop of its own accord. As well as maintaining the

current dynamic rate of expansion of renewables in the electricity sector and extending their use to the heat sec·
tor on a Significant scale, considerable additional sup· port measures to encourage much greater efficiency in

use and conversion of energy would be required if the 2050 climate protection larget is Lo be met on time by this strategy. Expanding renewables and increaSing efficiency are measures that take effect relatively quickly, so

as long as the necessary support measures impact fast, they allow the restructuring process to run more harmoniously than in the CCSMAX case described above. Major conversion of energy infrastructures would be required, but this could be realised in stages. A strategy concentrating especially on energy productivity also makes sense in broader economic terms because many of the efficiency measures represent the most economic option for climate protection regardless of what measures are taken on the supply side. If external costs were included the overall economic situation would be even

more favourable. To that extent this scenario represents

an 'ideal strategy' but one which demands that very effective energy policy decisions be taken quickly, especially a clear rationalisation and expansion of energy efficiency policy. In the longer term this scenario necessitates considerable structural changes, increasing the network and system integration of renewables on the electricity side, integrating energy import structures (e.g. electricity from solar thermal power plant in North Africa) and greatly expanding district heating systems.

To pursue both strategies 'at full steanl' until 2020 (efficiency and expansion of renewables following NATP until 2020; CCS development as in CCSMAX), but then

to largely drop one of Lhe options would not seem to be a sensible way to proceed. Consequently, the third
scenario discusses the extent to which the two strategies could be combined compatibly in a forward-looking strategy.

In a development corresponding with the BRIDGE scenario the timeframe for introducing CCS technologies and a hydrogen infrastructure is more relaxed than in CCSMAX because until 2030 the contribution required

Working Group WI, DLR, ZSW, PIK

## Summary

(02 reduction scenarios for Germany**~** RerwwiJble$


### II Natllral9i\s


### 1'1 Mineral oil Primary energy, PJ/a

14j)()0

12,000

10,000

8,000

6,000

4,000

1,00)

2000 200S**co~** CCSMAX storage in mio.l/a: 586

from this option (.HI remain relatively small. In the

event that CCS technologies turn out to be a sensible 

### and ecologically sustainable energy 

### option, even the level 

### of expansion required by 2050 does 

### not**encoun~** ter any fundamental barriers concerning required plant 

### capacity, infrastructure 

### modifications or sink capacity. In this case about 330 million t C0 2 1a wOl1ld have to
be captured and stored in 2050. For this, however, fos·**sil~fuclled** power stations 

### built before 2020 must 

### also be 1;iuitable for retroJitting with CCS, if the electricity

sector is to make a**~ubstantial** contribution to**reduc~** ing CO;;:, This should be taken into account in current ongoing 

### power station planning, 

### and where possible plant should be designed to be 'capture ready',



### An energy policy following the BRIDGE strategy will definitely 

### demand a general intensification 

### of energy 

### policy in all the listed field, if long-term climate protection goals are seriously to be achieved, So including 'CCS technologies' as an additional climate protection option should not serve as an excuse for neglecting the strategy clements of 'energy efficiency' and 'renewables'



### as the process intensifies. Instead these**~holiid** be**mobi~** Used by 2020 at least to the extent that they can**con~** tinue to 'take oW thereafter ifCCS technologics 

### should

turn out to be unworkable on the desired scale in the

RECCS ProJI?(I 

### IlilI (oalfur((S'Ii,


### III ligni1e • Nuclear

BRI])IlE NAIP

328 

### 21

Fig, 8: 

### Pom"yenergy structure today and in 

### the lce,a,iol for 2050

energy sector. At the same time, this timeframe 

### offers the opportunity to explore the development and cost potentials 

### of CCS technologies thoroughly and without massive pressure 

### of time, BUl 

### the successive**introduc~** lion 

### of CCS <::ould help as an ancillary element to make it easier to maintain the sustained impetus for further efficiency increases and 

### a greater expansion 

### of renew" abies than would possibly be the case with the signifi

### cantly higher hurdles in the NATP scenario, This could identify ways 

### to soften resistance 

### and to offset obstacles that remain insurmountable despite massive support and energy policy intervention, In view of the real**con~** stellations of interests and different 

### evaluatiOils of tech

### nology options 

### in the field 

### of energy, especially in the global context, a development following the BRIDGE scenario can 

### be regarded 

### as a 'pragmatic' 

### strategy.

A cost comparison of renewables and CCS technologies for electricity and hydrogen production shows no economic advantages for the CCS option at the point of its possible introduclion around 2020. The latter would then 

### require CO, 

### prices between €40 

### and €SOlt CO, 

### if it is to be attractive to private investors in place of conventional electricity generation from fossll fuels. Even 

### after 2020 renewable energy technologies will probably continue to have exploitable cost degression potentials,

### 22

whereas the cost of generating electricity from coal with CCS will 

### probably remain roughly constant, assuming

a corresponding degree of technical development. If we 

### factor in the external costs, we find further advantages for the development path building on renewables and
energy efficiency. From today's perspective, the relative profitability of CCS and renewables is associated 

### with diverse imponderables. The above assessments for
rene".'ables work on an assumption of dynamic global 

### market developments allowing very considerable cost degression potentials to be exploited via mass production and learning curve 

### effects.

One obstacle to a comprehensive CCS strategy could
also be lhat a strategy building largely on CCS would 

### require the earlier introduction of (Iow·C0 2 ) 

### hydrogen

on a**bro~d** 

### s(ale, which is associated with great infrastructure challenges, whereas a 

### strategy orientated on NATP would not require this on an appreciable scale until the 

### middle of 

### the century.

From the aforementioned aspects it 

### follows that a rigorous strategy based on the NATP scenario could also represent the more favourable option in 

### broader economic terms in the medium to long term and $hould thus be the aim of 

### energy polky. At the same time, it 

### would be recommendable to continue to subject the CCS option to thorough scrutiny and in particular a realistic practical demonstration, in 

### order to possess after a decade more 

### precise knowledge of the potential and limits of this set of technologies. [f it then turned

out that in 

### terms of efficiency 

### and expanding 

### renewables the restructuring of the global energy supply can 'only' proceed at the intensity described in BRIDGE, then CCS would be available as an additional climate protection option.



### Requirements for Successful International Implementation of C(S

rlhe concluding part of the study broadens the**perspec~** 

### tive to examine whether CCS is necessary from a global perspective 

### in order to meet ambitious climate**protec~** 

### tion targets and how an institutional framework can be established to sensibly regulate the risks of CCS.

The 

### role of CCS in the 

### context of other technology options**~** 

### i.e. in particular 

### the expansion of renewables

- was analysed 

### by meanS of an economic scenario**analy~** sis. Models to maximise 

### global social 

### welfare for a given limitation of the atmospheric CO 2 

### concentration were chosen by 

### simulating the progress 

### over time 

### of implementation of the three named options (and in the process including the technological learning effects). Central uncertainty 

### factors that have a strong influence on 

### the implementation of CCS and on the costs of climate protection were identified and interpreted by means of sensitivity analyses: 

### SumlTlary

• Learning rates for CCS and renewables influence 

### the cost reduction curve of 

### the technologies and 

### thus: their application. The qUicker 

### the cost-cutting potential of 

### renewables is reaUsed and 

### the slower that of CCS takes effect, the less CCS will be used. However, in both fields of technology as yet**llnfore~** 

### seeable development leaps and costs that cannot be reduced through learning effects (e.g. for fuels) could have a 

### strong influence 

### on their respective future market shares.

• Leakage rates (quantifying the slow escape of CO, from storage formations) must be 

### well below 

### 0.1 %


### per year if CCS is to be used efficiently at all.

• The discount rate determines the weighting 

### of consumption 

### over the 

### course of the planning 

### period. If a high discount rate is chosen

- giving welfare in the present a 

### higher weight and consequently 

### resulting in less being invested in renewables

- CCS gains and greater use of renewables 

### is shifted back


### to a later date. This occurs above 

### all when realising 

### learning rates in renewabJes requires 

### high iniw 

### tial investment compared with CCS.

G The 

### rising cost of 

### exploration and extraction associated with possible shortages of fossil reSOurces 

### has a strong effect on 

### the role of CCS. BecaLlse 

### of the attractiveness 

### of fossil fuels, 

### if their costs of do
not rise until relatively 

### lale, CCS will 

### be used exten· sively in order to meet 

### the set climate 

### protection target at all. But under 'peak oil' scenarios, which predict rapidly rising costs due to depletion of oil

reserves, the substitution of various fossil fuels could occur considerably earlier, which would reduce the demand 

### for 

### ces, However, the timeframe and interrelationships of these effects are not yet 

### fully understood.

" The use of CCS is worthwhile even if the time when CCS technologies become available for largescale application is delayed by several 

### decades. But 

### if CCS 

### were not available until 2050 

### the amount of CO 2 

### stored to meet climate 

### protection targets would be reduced considerably because it would then be more worthwhile to step up implementation of renewables from the outset.

The outcome of the economic scenario analysis is that
at the global level CCS can make 

### a tangible contribution

to 

### meeting ambitious climate protection targets. CCS

can fulfil a 

### 'bridging function' of a.voiding emiSSions



### on a scale that renewables and efficiency improvements
cannot achieve 

### on their own, and in 

### that context the
two technology options can complement one another, There can be no doubt. however, that in the long term

a sustainable reduction of climate change is achievable
in the 

### energy sector only through renewables and high
energy efficiency.

Working Group**'~n. D~R.** **~SW,** PIK

### Summary

Overall, according to the calculations, keeping the atmospheric concentration of CO 2 below 450 ppm over the course of the twenty-first century could be achieved
with a relative loss of 0.6 % of global GDP compared with the**businc&s~as~usual** trajectory. in the process of which a lotal of approx, 456 Gle (or 1,672 Gt CO 2 )
would have to be captured and stored. These results should be understood as plausible**mjJ~rangc** figures

- assuming a leakage fate 0[0.05 % per year and a**learn~** 

### ing rate for renewables of 15 %.**~fhe** 

### precise figure for
cUlilulative storage and the cost reduction will depend



### on the development of the investigated uncertainty file>

tors. The model calculations show thal with a**combi~** 

### nalion of both measures (renewables plus increased efficiency**a~d** CCS) 

### it would be possible to a.chieve ambitious global climate protection targets at a**rela~** tively small toss of economic grO"'-'ih, 'lhe calculated growth losses are 

### relativised still further if the necessary investments in measures for adapting to climate change

are factored in.

Large-scale introdu<.:tion 

### of CCS presumes the 

### implementation 

### of an institutional frarnework 

### that sensibly regulates the risks of CCS and offers incentives to use the safest possible storage 

### options.

b.·tany details of the national and international legal**situ~** 

### atian have yet 

### to be darified, and special frameworks for CCS have 

### yet to be developed. Tn view of the**long~term** nature of e0 2 storage, tbe principles of environmental 

### law require legislators 

### to ensure 

### there are suitable 

### rules for dealing with future risks and to strike a 

### suitable balance 

### between business liability for harm caused and the ultimate responsibility of the state. Monitoring sinks and defining an appropriate leakage rate are particularly important here. BecaLlse of the transfrontier effects ofeeS, international agreements are impC'ratiVE'.



### As the economic analysis shm

... 

### 'ed, it 

### makes sense to embed CCS in international climate protection agreements. However, CCS is not yet included in the mechanisms of the UN Framework Convention on Climate Change. Guidelines for accounting fur the emissions 

### saved through CCS (and those that may be released again) have not yet been implemented. That would be



### an important precondition for being able 

### to include. CCS in the tlexiblt' mechanisms of the Framework Con

### vention on Climale Change. With regard to the debate between the two fundamental approa(hes to climate protection 

### agreements (cap and trade system and techn(')iogy protocol) C(5, with its technological challcnges that are yet to be mastered, could serve to illustrate that both approaches are possible and usefuL

Regulating responsibility for risks from 

## ecs could 

### be achieved 

### through tradable 

### (arbon sequestration 

### bonds, which the operator 

### of, CCS project would be obliged to purchase and which would be depreciated 

### proportionatel)' if leakage occurs, The bond system offers incentives for eJl1cient limitation of harm caused by CO 2 leakage and involves the financial markets and

RECCS Project 

### 23

through them the public (via investment decisions for safe CCS projects) in the control of risk::>. State revenues through devaluation 

### of bonds could be used 

### to pmmote renewables, thus balancing out the delay in their development resulting from the use of an unsafe stor

### age option.

# Structure of long Version

The long**vel'~inn** has 226 pages, 60 titbies .md 116 

### figures. It can he obtained as paper 

### \'ersion and electrouically at www.bmu.de.

Summar), of Theses



### Summary

Introduction and Background

I Status Quo and the Aim, of the Study 

### 2 Terminology
3 Driving Forces: The Attitudes of Relevant Groups


### to CO?, 

### Capture and Storage

II Technologies and Process Chains
4 An Overview of CCS Processes 5 CO 2 Capture Z.I,1ethods 

### tor Power Plant and Hydrogen Production 6 COl Transport
7 CO 2 Storage 8 Central Aspects of CO 2 Transport Infrastructure

III Comparative Analysis and Assessment 

### 9 Criteria for a Comparative Assessment of CCS 

### 10 Life 

### Cycle**Assessment~** 

### for SeI("ctcd CCS-Processes
II Other Ecological Assessment Criteria for CCS
12 Development of Electricity and Hydrogen Generation Costs with CCS
13 Other Energy Sector Criteria



### IV Systems Analysis: A National Perspective
14 Systems Analysis ofCCS Scenarios

V Global Aspects
15 CCS in the International Context

Appendix



### References

RECCS Prolect 

### 25

## 26 Table of Contents



# Table of Contents

Summary of Theses 15

Summary 21

Background and Introduction 21 Driving Forces and the Attitudes of Relevant Groups towards Carbon Capture and Storage 21 CO, Capture Methods 22 CO, Transport Methods 24 CO, Storage Methods and Capacity 25 Criteria fol' a Systematic Assessment of CCS 26 Comparative Life Cycle Assessments 27
Other Ecological Assessment Factors for CCS 30 Economic Comparison of 

## ces and Renewables 30 The Role of 

## ces inlndllstrialiscd Countries

- the Example of the
German Energy Supply System 32 Requirements for S1.lccessful International Implementation of CCS 34

Chapter 1 Stalus Quo and the Alms of fhe Study 36

Chapter 2 Terminology 38

Chapter 3 Driving r;orces; 'Ill':: Attitudes of Relevant Groups to CO 2 Capture and Storage 39

3,1

3.2

3.3

3.4 International and German NGOs

Industrial Associations and Companies

German Political Parties

German Ministries and Expert Committees
3.4.1 The Federal Ministry of Economics and Technology (BMWi)

Chapter 4 An Overview of CCS Processes

Chapter 5

5.1

5.2

5.3

5.4 Capture Methods for Power Plant and Hydrogen Production

Developments in Power Station Concepts with CO 2 Capture

Concepts for Moving towards**Large~Scale** Production of 

### Hl
5.2.1**Large~scale** 

### H2 Production Today (Steam Reforming of Natural Gas)
Learning Curves and Possible Cost Degressions

Relevant Applications for Energy Systems, Case Study Germany

Chapter 6 CO 2 Transport

--------- -------- 6.1 Physical State for Transport and Energy Required for Compression
and Transport

6,2

6.3 Transport Options
Transport Costs 41



### 42

42

43 

### 43

45

50

50

58 58

59



### 60

61

63

65

68

Worklnc Group WI, DLR ZSW, PIK

### Table of 

### (ontenll

Chapter 7
CO 2 Storage**~-~~** Overview of Methods 7.1

7,2

7.3 

### Relevant Global Storage Options and Their Potential

Assessment of the Storage Options in Germany as an Example of an Industrialised Country



### Chapter 8 

### Central Aspects of CO 2 

### Transport Infrastructure

8.1

8.2

8.3

8.4

85

8.6 Interdependency bet ween Et1crgy U.se and Freight Transport



### Determinants of Additional Freight Transport with CCS

Technical Aspects of Bulk Transport Capacity


### Networkability 

### of Modes arTransport

Conclusions

Case Study: TransporL**OptiQn~** for a 700 MW Coal· tired Power Station



### Chapter 9
Criteria for a Comparative Assessment of CCS

Chapter 10 

### Life Cyde Assessments for Selected**CCS~Processes** 10. I 

### Methodology

10.2 

### Mathemalical Melhodology Captured versus Avoided CO,

10.3 Plant and Processes for Conventional Electricity Generation with CCS

10,4 Plant for Generating Electricity from Renewables

10,5 Analyses of Individual Electricity Generating Systems



### 10.6 Comparison of Energy Generation Systems

10.7 Sensitivity Analyses of Electricity Generating Systems

10.8 Conclusions for Electricity Generation

10.9 Plant and Processes for Conventional Hydrogen Production with CCS



### 10.10 Plant for Producing Hydrogen Using Renewables

10.11 Individual Analyses of Hydrogen Production Systems

10.12 Comparison of Hydrogen Production Systems

10.13 Conclusions for Hydrogen Production



### Chapter II 

### Other Ecological Assessment Criteria for CCS

I J.I 

### CO, Capture

11.2 CO 2 Transport

1 L3 

### Storing CO,



### I 1·4 A Comparison of Strategies

Chapter 12 Development of Electricity and Hydrogen Generation Costs with CCS



### 12.1 Future Electricity Generation Costs Taking Account of Technological Developments. Fuel Price Rises and Cost of CO 2 Emission Certificates

REUS Pro,le(t 71

71



### 73

76

78

78



### 80

81

83

83

86

88

93

93



### 98

99

IUS

105

107

113

118

119

123

123

125

126

127

127

127

t28



### 130

135

135 

### 27

### 28 Table of Contents

12.2 Costs of Hydrogen Production from fossil Resources with CO 2 Coapture 148 12,2,1 Hydrogen Production with 

### CO, Capture 148



### Chapter 13 Other 

### Energy Secto::r_C::n::' t::e

__ r1

__ a

_____ _ 13.1 Social Acceptance

13,2 

### Transferability of'Iechnology to 

### Developing Countries

13.3 Technology Leadership and ExporlOpportunities



### 13.4 Import Dependency

13.5 Security Policy Implications

13,6 Vulnerability 

### and Comptexity 

### of the System

13.7 Conflicting Alternative Uses



### Chapter 14 Systems Analysis of CCS Scenarios

14,1 

### CCS in the Energy 

### Economy

14.2 Scenario Analyses: Assessment of the Strategic Importance of CCS

14.3 Conclusions of the Scenario Analysis for Germany

14.4 Applicability of Results to Other CQuntries



### Chapter 15
CCS in the International Context

15.1 The Significance of CCS as a Climate Protection Option

15,2 CCS in a Portfolio afClimate Protection Strategies! Analysis of Uncertainty Factors

15.3 Requirements for an Institutional Framework for CCS 

### ,---

15.3.1 The Basis for an Institutional Framework: "Cap and Trade"

Appendix

Contents 155

155

155

156

156

156

157

158



### 159

159

165

175

179

181

181

183

188

199



### 197

A.l 

### Physical Properties 

### of CO, 199

A.2 

### CO, Capture Methods (to 

### Chapter 5) 

### t99 A,2,1 Chemical/Physical Absorption 200 A.2,2 Adsorption on Solids 201 A,2.3 Cryogenic Distillation 201 A,2,4 Membrane Method 202 A,2,5 

### High-temperature Methods 202 A.2.6 Conclusions 203

A.3 Worldwide Overview 

### ofeeS mjeets (to Chapter 7) 203 A.3.1 Projects within the EU 206 A.3.2 International Activities and Political Strategies 210 A,3,3 CCS 

### Projects in 

### Germany 213

A.4 Central 

### Issues for Planning 

### a CO, Transport Infrastructure 

### (to Chapter 

### 8) 214

A,S Data Used 

### for Analysing Mass Flows of Fuel and 

### CO, (to Chapter 10) 214

References 

### 217

W'orklng Group WI, DlR.lSW. PIK

### This publicatioo is based 00 the Germao research Prolect "iikologische Einordnung und strukturell·ijkonomisdlerVerglelch regeneratiyer Energiete<hnologi.n mit and.r.n Optlon.n ,um Klim.schutz, .pedell d.r RUckh.ltung und Sp.lch.rung von Kohl.ndloxid bei der Nutzung 105lII.r Primarenergl.n" 00 behalf of the federal Mioistry for the Environment, Nature (onservatioo and Nudear Safety.

(ontact: 

### Federal Ministry for the Environment, Natur. (on\erv.llon and Nuclear Safety (BMUI Dep. Public Relallon.
11055 

### Berlin' Germany Telefax: +4930 1830H044 

### Homepage: www.bmu.de

This brochur. is part olthe public relations work olth.
Federal Ministry 

### for the Environment, Nature Conservation and Nuclear 

### Safety. It is distributed f

..

e of 

### chal1J' and is not intended for sale. Th. brochure is printed on lOa % 

### re<ycled paper.

### Letter ID: 0347

Commenter: Mary Munn Organization: Fond du Lac Reservation

Letter ID: 0347 Comment ID: 27891 Letter Lines: 47 to 51

Comment Code: 5000 5. Comments on the Proposed Rule (out of NODA Scope)

Comment: General The proposed rule is quite specific and seeks to compartmentalize

comments only to the endangerment that may be caused to underground sources of drinking water (USDW). However, the proposal goes on to state that the Class VI injection wells are to be one approach "that could be deployed to reduce CO2

emissions to the atmosphere and help to mitigate climate change."

Individual Response: This comment pertains to EPA’s proposed GS rule (73 FR 43492) and is outside the

scope of the Notice of Data Availability. Please see responses to comments on the proposed rule for

EPA’s response to similar comments.

Letter ID: 0347 Comment ID: 27892 Letter Lines: 52 to 61

Comment Code: 5700 5.14. Comments on Other Aspects of the Proposed Rule

Comment:
While such specificity allows for a focused approach, if approved, it may allow

Class II wells to be used for GS of CO2 under the rule. The use of Class II
wells for GS of CO2 will likely allow carbon credits in one form or another,

even though the injected CO2 would be used to enhance the extraction of

additional fossil fuels (oil or natural gas), which when consumed releases CO2, impeding rather than mitigating CO2 emissions.

If the proposed wells are to be a part of a climate mitigation strategy, supporting data must be supplied to verify that goal.

Individual Response: This comment pertains to EPA’s proposed GS rule (73 FR 43492) and is outside the

scope of the Notice of Data Availability. Please see responses to comments on the proposed rule for

EPA’s response to similar comments.

### Letter ID: 0347 Comment ID: 27893 Letter Lines: 63 to 129

Comment Code: 6000 6. Other Comments that are Out of Scope for the NODA

Comment: Assessment of the Proposed Rule The proposed rule repeatedly references climate change mitigation by the injection of CO2 as the justification for the need for

the new class of injection well:

Summary: "EPA is proposing Federal requirements under the Safe Drinking Water

Act (SDWA) for underground injection of carbon dioxide (CO2) for the purpose of geologic sequestration (GS). GS is one of a portfolio of options that could be deployed to reduce CO2 emissions to the atmosphere and help to mitigate climate change."

And "If finalized, this proposal would help ensure consistency in permitting underground injection of CO2 at GS operations across the U.S. and provide requirements to prevent endangerment of USDWs in anticipation of the eventual

use of GS to reduce CO2 emissions."

In Part II "What is the EPA Proposing" the proposition reiterates:

"In addition to protecting USDWs, today's proposed rule provides a regulatory

framework to promote consistent approaches to permitting GS projects across the

U.S. and supports the development of a key climate change mitigation technology."

Under Part II A. "Why Is EPA Proposing To Develop New Regulations To Address GS
of CO2?" Part II. Section 2, states: The Intergovernmental Panel on Climate Change (IPCC) has concluded that much of the warming in recent decades is very likely the result of human activities (IPCC, 2007). The burning of fossil fuels (e.g., from coal fired electric plants and other sources in the electricity and

industrial sectors) is a major contributor to human induced greenhouse gas
emissions.

Fossil fuels are expected to remain the mainstay of energy production well into
the 21st century, and increased concentrations of CO2 are expected unless energy producers reduce the CO2 emissions to the atmosphere. The capture and storage of

CO2 would enable the continued use of coal in a manner that greatly reduces the

associated CO2 emissions while other safe and affordable alternative energy

sources are developed in the coming decades. Given the United States' abundant

coal resources and reliance on coal for power generation, CCS could be a key mitigation technology for achieving domestic emissions reductions"

### And:

"Congressional climate change legislative proposals (the McCain

‐ Lieberman bill

S. 280, the Bingaman

‐ Specter bill S. 1766, and the Lieberman

‐ Warner bill S. 2191) indicate that CCS has the potential to play a significant role in climate change mitigation scenarios."

And:

"Today's proposal provides a regulatory framework to protect USDWs as this key

climate mitigation technology is developed and deployed."

The allusion of mitigating climate change or reducing CO2 emissions by geologic sequestration cannot be fairly used as persuasive point for this rule without providing data demonstrating the mass balance of energy and carbon dioxide in
the whole system. A great deal of analysis has been completed and posted on the

docket of cost and incremental cost within the proposed rule for CCS and GS implementation but no analysis is made in terms of the actual amount carbon

dioxide that will be sequestered in relation to the amount of carbon dioxide

emitted throughout the process (Cost: EPA

‐ HQ

‐ OW

‐ 2008

‐ 0390

‐ 0073 and EPA

‐ HQ ‐ OW

‐ 2008

‐ 0390

‐ 0094).

A mass balance of the participating fossil energy processes, generating the CO2,

must be evaluated to determine if any real reduction in CO2 can be made. CO2 is
emitted during the excavation and transport of the fossil fuel to a power plant.

Additional power will be required, and will emit additional CO2, to provide the

energy to extract the CO2 from the emission stream, to compress, transport, and

to inject the CO2 into a geologic formation.

Individual Response: This comment pertains to EPA’s proposed GS rule (73 FR 43492) and is outside the

scope of the Notice of Data Availability. Please see responses to comments on the proposed rule for

EPA’s response to similar comments.

Letter ID: 0347 Comment ID: 27894 Letter Lines: 131 to 157

Comment Code: 6000 6. Other Comments that are Out of Scope for the NODA

Comment: Very little data is available to evaluate the energy balance of various carbon
capture processes. The evaluations available limit the efficiency of carbon

### capture (CC) to a percent recovered from the feed stack to the emission stack. Capturing the carbon is very energy intensive and may increase energy demand by

up to 50%. (www.lowtechmagazine.com accessed October 27 2008).

According to Greenpeace International: False Hope: Why carbon capture and
storage won't save the climate, "capturing and storing carbon uses lots of

energy; anywhere from 10

‐ 40% of a power station's capacity. An energy penalty of just 20% would require the construction of an extra power station for every four

built. These reductions in efficiency will require more coal to be mined, transported, and burned, for a power station to produce the same amount of

energy as it did without CCS."

The attached summary of a study by Wuppertal Institute, the German Aerospace

Center (DLR), Zentrum fur Sonnenenergie ‐ und Wasserstoff

‐ Forschung Baden ‐ Wurttemberg (ZSW) and the Potsdam Institute for Climate Impact Research (PIK)

for the German government (the full report available at: www.wupperinst.org,

accessed on line Dec. 23 2008) offers an in depth study of CCS that evaluates

the various power plant designs, transport, and storage costs; accesses life cycle, ecological criteria, carbon neutrality etc. Estimates in the study show a
20 to 40% increase in energy consumption and the process will only lower

emissions of CO2, ignoring the increases of other greenhouse gases (GHG). [SEE P. 6 OF

EPA

‐ OW

‐ 2008

‐ 0390

‐ 0347.PDF FOR THIS DOCUMENT.]

Consuming an additional 20 to 50% more coal to energize the capture of CO2 is a questionable tactic that must supported by transparent data analysis.

Individual Response: This comment is outside the scope of the Notice of Data Availability and the UIC Program’s authority under the GS rulemaking.

Letter ID: 0347 Comment ID: 27895 Letter Lines: 159 to 179

Comment Code: 6000 6. Other Comments that are Out of Scope for the NODA

Comment: Even as this proposed rule is being considered, the EPA is soliciting "applications to conduct research to support the development of sound risk
management strategies for the underground injection of anthropogenic carbon

dioxide (CO2)" (accessed online October 6 2008 http://es.epa.gov/ncer/rfa/2008/2008_star_gsc02.html). The technology for GS of

CO2 is not yet available or known to be safe.

### Social Justice: The United Nations Environmental Progamme states: "Globally

around $300 billion or 0.7 per cent of global GDP is being spent on energy subsidies annually. The lion's share is being used to artificially lower or reduce the real price of fuels like oil, coal and gas or electricity generated

from such fossil fuels. Cancelling these subsidies might reduce greenhouse gas
emissions by as much as six per cent a year while contributing 0.1 per cent to global GDP."

Mr. Steiner added: "Whereas fossil fuel subsidies are an example of a blunt policy instrument, perpetuating old and inefficient economic models, the CDM is

an example of a more intelligent, market

‐ based mechanism that is fostering the

transition to a modern Green Economy". (Accessed online Nov. 14, 2008 http://www.unep.org/Documents.Multilingual /Default.asp?DocumentID=543&ArticleID=

5902 )

Individual Response: This comment is outside the scope of the Notice of Data Availability and the UIC Program’s authority under the GS rulemaking.

Letter ID: 0347 Comment ID: 27896 Letter Lines: 181 to 187

Comment Code: 6000 6. Other Comments that are Out of Scope for the NODA

Comment: Recommendations:

∙ A thorough mass balance of the CO2 generated in the participating fossil

energy processes, generating CO2 must be demonstrated to prove the feasibility

of the proposal; including mining and transport of the fossil fuel to power plants, extraction and compression of the CO2 emissions, transport, and injection the CO2 into a geologic formation.

Individual Response: This comment is outside the scope of the Notice of Data Availability and the UIC Program’s authority under the GS rulemaking.

Letter ID: 0347 Comment ID: 27897 Letter Lines: 189 to 192

Comment Code: 6000 6. Other Comments that are Out of Scope for the NODA

Comment: ∙ If carbon credits are developed, they must not apply to other UIC wells except specific Class V experimental wells. To use sequestered carbon dioxide under the

### auspices of this rule, to enhance the recovery of additional fossil fuels is imprudent and illogical.

Individual Response: This comment pertains to EPA’s proposed GS rule (73 FR 43492) and is outside the

scope of the Notice of Data Availability. Please see responses to comments on the proposed rule for

EPA’s response to similar comments.

Letter ID: 0347 Comment ID: 27898 Letter Lines: 194 to 201

Comment Code: 5200 5.4. Comments on the Proposed Financial Responsibility Requirements (146.85)

Comment: ∙ Liability issues must be clarified in regard to human welfare and

environmental protection rather than ensuring the financial viability of the

commercial entities of power plants, pipeline, and well operators. Proponents
wish to diminish liability for CCS and GS activities (EPA

‐ HQ ‐ OW

‐ 2008

‐ 0390

‐ 0150.1) and EPA must explicitly recognize the threat of an uncontrolled release of CO2 to human life. Acknowledgement of the potential hazard, in a manner similar to OSHA guidelines on "gases, vapors, fumes, dusts,

and mists ‐ 1926.55" would be beneficial.

Individual Response: This comment pertains to EPA’s proposed GS rule (73 FR 43492) and is outside the

scope of the Notice of Data Availability. Please see responses to comments on the proposed rule for

EPA’s response to similar comments.

Letter ID: 0347 Comment ID: 27899 Letter Lines: 203 to 207

Comment Code: 6000 6. Other Comments that are Out of Scope for the NODA

Comment: ∙ Fond du Lac will defer to the experts in the case of pipeline and well integrity and the long term safety of geologic sequestration of carbon dioxide.
However, the skill of deep drilling brings to mind the mudflow disaster of Sidoarjo Porong, East

‐ Java Indonesia, which began in May 2006 and is still flowing to this day.

Individual Response: This comment is outside the scope of the Notice of Data Availability and the UIC Program’s authority under the GS rulemaking.

### Letter ID: 0347 Comment ID: 27900 Letter Lines: 209 to 211

Comment Code: 5200 5.4. Comments on the Proposed Financial Responsibility Requirements (146.85)

Comment: ∙ Financial Assurance should be required for any unforeseen effects of a given project.

Individual Response: This comment pertains to EPA’s proposed GS rule (73 FR 43492) and is outside the

scope of the Notice of Data Availability. Please see responses to comments on the proposed rule for

EPA’s response to similar comments.

Letter ID: 0347 Comment ID: 27901 Letter Lines: 214 to 225

Comment Code: 6000 6. Other Comments that are Out of Scope for the NODA

Comment: Although the effort made to address the serious issues of climate mitigation through CCS is greatly appreciated, the effort largely appears to mitigate CO2

emissions via a complex system that will, in reality, increase fossil energy consumption. With projected consumption to increase more than 30% by 2030 and

CCS adding at least 20% additional demand, one may wonder if this proposal
equates to yet another subsidy for fossil fuel industry.

The absence of analysis of the carbon neutrality of this project is a serious

omission. An analysis of this kind should have been the first step in evaluating

this proposal, yet it is not addressed in the rule or in any of the supporting
documentation. An endeavor of this magnitude should be demonstrably carbon

neutral and hopefully operate as a true carbon sink.

Individual Response: This comment is outside the scope of the Notice of Data Availability and the UIC Program’s authority under the GS rulemaking.

Letter ID: 0347 Comment ID: 27902 Letter Lines: 227 to 230

Comment Code: 6000 6. Other Comments that are Out of Scope for the NODA

Comment: The commitment of resources; human, material, and capital, required to construct
the network of pipelines and wells for a project that is most likely energetically untenable, cannot be supported without a proper evaluation of

### carbon throughput of the entire process.

Individual Response: This comment is outside the scope of the Notice of Data Availability and the UIC Program’s authority under the GS rulemaking.

Letter ID: 0347 Comment ID: 27903 Letter Lines: 232 to 256

Comment Code: 6000 6. Other Comments that are Out of Scope for the NODA

Comment: This rule is written for the existing energy production system. The reliance on fossil energy must change to meet the challenge of climate change. Barriers to
the success of alternate sources of energy must be removed so the issue can be

faced head on. This rule will impede and obstruct progress for those competing
industries.

The resources required to pursue this undertaking will be in direct competition
with efforts focused on sustainable energy sources and alternative, arguably

more effective carbon sequestration, utilizing wetland restoration, improved agricultural methods, and sustainable forestry practices that have numerous and

vital fringe benefits.

Experts in carbon sequestration know that utilizing biologic methods of carbon
capture is cost effective and will include economic benefits. For example,

wetland protection and restoration will not only sequester carbon but will purify water, impede drainage (flooding), and replenish aquifers. Many avenues could be used to reverse engineer the activities that drained these wetlands.
Many studies including the Kyoto Protocol Wetland Restoration and Management and

the Wilderness Society Forest Carbon Report support these alternative carbon sequestration mechanisms.

Reduction of carbon emissions to the atmosphere is the primary driver for this

new class of well, proof that carbon capture and sequestration will provide a

net removal of CO2 must be provided else any reference to the reduction of CO2

emissions or climate mitigation must be removed from the document.

Individual Response: This comment is outside the scope of the Notice of Data Availability and the UIC Program’s authority under the GS rulemaking.